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April 26th, 2016
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The latest news

OECD Seeks Feedback on Hard-To-Value Intangibles Guidance
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May 23rd, 2017
OECD invited interested stakeholders for public comments on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.
Background: Hard-to-value Intangibles
US to Consult Destination-Based Taxation And Border Adjustments
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May 23rd, 2017
The House Committee on Ways and Means published a document prepared by the staff of the Joint Committee on Taxation that provides an overview and analysis of destination-based taxation and border adjustments. The document has been published ahead of a public hearing on border adjustments and international tax reform that takes place on May 23.
Schelling - Agreement On A European Tax On Financial Transactions Is Within Reach
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May 23rd, 2017
On May 21, during the interview with Austrian broadcaster ORF, Austrian Finance Minister Hans Joerg Schelling said that an agreement on a European tax on financial transactions is within reach as more countries sign up for the final version of the measure and the new French government gives it a final review, Reuters reported.
Background
We Provide Solutions - Let's Talk Business!
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May 23rd, 2017
TPA Global provides solutions in the area of BEPS, Value Chain Analysis for multinationals along with variety of tax, business and educational technologies. Tax departments are facing an increased compliance burden and fewer opportunities for optimization.
China Further Develops Its Transfer Pricing Regime - Issuance Of Bulletin 6
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May 22nd, 2017
The China State Administration of Taxation (SAT), on March 17, 2017 has issued new transfer pricing rules: Bulletin 6 – the “Administrative Measures on Special Tax Investigation, Adjustment and Mutual Agreement Procedures”, which has taken effect as of May 1, 2017. Bulletin 6 revised and refined certain provisions stipulated in the 2009 "special tax adjustment implementation measures (Trial)" (Circular 2) and further clarified the transfer pricing investigation procedures and adjustment methods applied by the Chinese tax authorities.
LATAM Country Summaries Update
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May 19th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates
EU Commission Requests France To Abolish Certain Withholding Tax
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May 18th, 2017
The European Commission released its “May infringements' package: Part 1: key decisions” including Commission’s request to France to abolish withholding tax imposed on non-resident companies in deficit.
Free Movement Of Capital
The Netherlands Opens Consultation On Dividend Withholding Tax For Holding Cooperatives
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May 18th, 2017
The Dutch Government published a draft law containing new obligation to withhold withholding taxes for so-called holding cooperatives. The Dutch Government invites interested parties to provide their feedback on the draft law.
US Companies Demand Higher Cuts On Offshore Profits
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May 16th, 2017
Major US multinationals push US Government to further deepen the tax break on corporate profits being held offshore. Some of the lobbyists said that in order to bring their corporate profits to the US, they need a sharply reduced tax rate even below the recently proposed reduction to 10 percent, Reuters reports.
Research Paper Provides Perspectives on Corporate Tax Avoidance
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May 16th, 2017
The US academics Jaron Wilde and Ryan Wilson published a paper summarizing the academic perspectives on corporate tax avoidance highlighting the main developments over the last decade.
The Context
G7 Finance Ministers Address Taxation Digital Economy
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May 16th, 2017
During the meeting on May 12-13 in Italy, G7 finance ministers and central bank governors expressed the need to address the tax challenges associated with the digitalization of the economy. During the event, U.
Value Chain Analysis Workshops for Corporates.
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May 12th, 2017
Free for booking: Amsterdam, May 30, 2017.
The Bridge to Align the Operating Model, Corporate Governance Framework and the Tax/Transfer Pricing Structure of an MNE.
German Finance Minister Claims Malta Has Become The Panama Of Europe
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May 11th, 2017
Germany's North Rhine-Westphalia finance minister Norbert Walter-Borjans claimed that Malta has become the Panama of Europe after a data leak revealed by German Journalists that there are 70,000 offshore companies in Malta. In response, Ministry of Finance informed that public register can be accessed online while its Finance Minister Edward Scicluna tweets "Pull another one".
Australia Releases Budget 2017-18 Documents
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May 11th, 2017
During the Federal Budget 2017-18, Australian Treasurer Scott Morrison announced that Australia will introduce hybrid mismatch provisions applicable to banks and financial institutions and tighten its multinational anti-avoidance law (MAAL). The Budget documents and a new Black Economy Taskforce interim report have been published.
OECD Launches Facility To Disclose CRS Avoidance Schemes
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May 9th, 2017
The OECD launched a disclosure facility on the Automatic Exchange Portal which allows interested parties to report potential schemes to circumvent the CRS. The OECD also informed that over 1800 relationships are now in place to automatically exchange CRS information between tax authorities.
PANA Questions Channel Islands, Gibraltar, and Madeira
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May 9th, 2017
On May 9, the PANA Inquiry Committee held a public hearing on the “Cooperation in tax matters with European jurisdictions,” during which Members of the EU discussed tax regimes with representatives of the Channel Islands, Gibraltar, and Madeira.
Background
EU Parliament Releases CCTB and CCCTB Briefings
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May 9th, 2017
The European Parliament informed that it released briefing for the Common Consolidated Corporate Tax Base (CCCTB) Project. The briefing provides background information, information about the proposal and its impact as well as views of advisory committees, national parliaments and stakeholders.
Amsterdam Workshop Value Chain Analysis for Corporates
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May 6th, 2017
Thursday, 30 May 2017 (second Amsterdam workshop)
Value Chain Analysis Workshop for Corporations - the bridge to align the operating model, corporate governance framework and the tax/ transfer pricing structure of MNE.
Dutch Railway Company Again Accused Of Tax Evasion
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May 5th, 2017
Dutch railway company NS, which operates services in Germany and Britain, continues to avoid corporation tax through its subsidiary Abellio in Ireland, despite the Dutch government’s warning to abstain from using this tax avoidance scheme, Dutch Newspaper Trouw reported.
Background
Moscovici Details New Measures Against Intermediaries Who Help Tax Evasion
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May 5th, 2017
The PANA Committee held a hearing with Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, who gave details of the planned EU blacklist of tax havens to be published this year, addressed the further work on the role of intermediaries and informed about recent exchanges with members of the new US administration.
Background
Tech Giants Forced to Book Profit in Australia
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May 2nd, 2017
Recently published financial results of Google and Facebook revealed significantly higher Australian revenue and profit following Australia's implementation of tougher anti-avoidance measures including the Multinational Anti-avoidance Law (MAAL) and the Diverted Profits Tax. The companies acknowledged the new laws contributed towards the large boost in booked revenue.
Russian Federation And Japan Sign New DTA
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May 2nd, 2017
The Government of Japan and the Government of the Russian Federation have agreed in principle on a new Tax Convention.
Previous Tax Convention
European Parliament Adopts Hybrid Mismatch Rules
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May 2nd, 2017
The European Parliament adopted a legislative resolution on a proposal for a Council Directive amending the Anti-Tax Avoidance Directive on hybrid mismatches involving third countries (ATAD 2). The report will be considered for final approval by the European Council.
EU PANA Committee Presents Studies on Tax Evasion
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April 28th, 2017
The EU PANA Committee has presented the findings of three studies focusing on the impact of money laundering and tax evasion on EU Member States’ economies and finances. The Committee also presented the roles played by Member State administrations in fighting tax evasion and money laundering.
Italy Updates Transfer Pricing Rules And Patent Box Regime
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April 28th, 2017
Italy publishes Decree n. 50 that implements changes to its transfer pricing and patent box regime, including arm’s length principle and updated list of intellectual property, MNE Tax Reported.
Trump Reveals New Tax Plan
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April 28th, 2017
US president Donald Trump proposed sharp reductions in individual and business income tax rates, reducing the “business tax rate” to 15 percent and moving to a territorial tax system.
Main Proposals
Transfer pricing in Hungary and Romania
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April 28th, 2017
"A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements"
Transfer pricing is a hot subject for companies operating in Romania and in Hungary. This is because the local tax authorities are focusing more on this topic, with the number of transfer pricing audits increasing significantly in the last few years.
Are you currently preparing your own Value Chain Analytics (VCA) for Tax/Transfer pricing purposes?
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April 26th, 2017
Free One to One Consultation (Reserve a slot with one of our Professionals!)
How are you preparing for your value chain in China?
The United Arab Emirates Sign The Multilateral Convention On Mutual Administrative Assistance in Tax Matters
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April 26th, 2017
On April 21, the OECD informed that the United Arab Emirates signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. By doing so, the United Arab Emirates became the 109th signatory to the convention.
Mossack: The Number Of US Tax-Shelters Increase After Panama Papers
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April 26th, 2017
Juergen Mossack, who partnered with Ramon Fonseca to create the Panamanian firm Mossack Fonseca, said in a document that the number of tax shelters has been decreasing in many tax havens while raising in the US jurisdictions such as Delaware or Nevada.
Panama Papers Adopts Transparency
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April 26th, 2016
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