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EU Advisory Body Proposes a Method To Allocate Residual Profits From Marketing Intangible
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July 19th, 2019
The EU Advisory Body has proposed a method to allocate residual profits from marketing intangibles with a four-factor formula as a way to adapt global tax rules for the digital age. The European Economic and Social Committee ( EESC ) adopted an opinion about taxation of the digital economy, noting that any changes on the allocation of taxing rights among countries should be coordinated globally, in order to harness the benefits of globalization.
US Senate Adopts Controversial Exchange Of Information In Their Ratified Protocols To Tax Treaties With Japan, Switzerland and Luxembourg
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July 19th, 2019
The U.S. Senate approved updates of tax treaties with Switzerland, Japan and Luxembourg that had been stalled for years over taxpayer privacy concerns. The updates approved a day after ratifying a similar update of a treaty with Spain.
French Parliament Approves The Reduction of Corporate Income Tax Rate
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July 16th, 2019
The French parliament approved legislation shifting the trajectory of the reduction in the corporate income tax rate that already enacted in the 2018 finance law.
Corporate income tax measures .
UN Releases Updated Tax Treaty Manual With Anti-Avoidance Language
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July 11th, 2019
The UN has published a new version of the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries . First published in 1978, the Manual is prepared by the UN’s Committee of Experts on International Cooperation in Tax Matters.
India’s Budget 2019-20: Expanding Lower Corporate Rate, Increasing Tax Rate For Higher Earners
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July 9th, 2019
India's Union Budget for 2019-20 was presented to Parliament, proposing changes to the tax laws starting 1 April 2019. This Finance Bill follows the interim budget announcement in February 2019 which was made ahead of the recent national elections.
Tax Technology - Big Tax Brother is watching you
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July 9th, 2019
Tax authorities are increasingly relying on technology for data gathering, exchange of information and analytics. Current digital systems can even provide real-time tax collections, re-conciliations and assessments.
The Next Generation of Benchmarking
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July 8th, 2019
Value Chain Analysis (VCA) was incorporated into the regulations following the OECD/G20 BEPS initiative (BEPS Actions 8 - 10), and subsequently, embedded in the OECD Transfer Pricing Guidelines 2017.
The importance of VCA in the OECD Transfer Pricing Guidelines, 2017, is revealed in their collective title: “ Aligning Transfer Pricing Outcomes with Value Creation ”.
Australian Global Resources Company To Pay $175 Million In Tax Dispute
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July 4th, 2019
BHP Group, the third-largest producer of the steel-making ingredient agrees to pay AUD250M (U$175M) to State Australia (Western) tax authority to end a dispute over royalties paid on iron ore shipments sold through its Singapore marketing hub.
The accusations of having underpaid iron ore royalties .
The UK to Adopt EU Double Taxation Dispute Resolution Regulations
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July 4th, 2019
UK HMRC has launched a technical consultation on the Draft Double Taxation Dispute Resolution (EU) Regulations 2019. The Regulations are for the implementation of Council Directive on tax dispute resolution mechanisms in the European Union.
Dutch Cabinet Submits New Bill Against Tax Avoidance
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July 4th, 2019
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2).
Implementation of ATAD2: Hybrid mismatches .
We Are Hiring - Junior Personal Assistant (part-time)
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July 2nd, 2019
TPA Global HQ in Amsterdam is looking for a Junior Personal Assistant (part-time) to join our team.
Are you pro-active, service-oriented, and eager to learn and want to grow as a PA? .
Taiwan Releases Guidance On The Application Of The Beneficial Owner To Be Aligned With OECD Approach
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July 2nd, 2019
Taiwan’s Ministry of Finance (MOF) released guidance to clarify the application of the term “beneficial owner” (BO) for tax treaty purposes. The Guidance aims to provide greater clarity for taxpayers as it specifies the situations where BO status will be granted or denied and aligns Taiwan’s position with the OECD Model Tax Convention Commentary, MOF practices and approaches taken by other countries.
EU Notes Launch of New Tax Dispute Resolution Mechanism
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July 2nd, 2019
As from June 2019, new EU rules come into force to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively between the Member States, making daily life easier and offering much more tax certainty for businesses and individuals experiencing double taxation issues.
Resolution of tax disputes in the European Union .
Saint Lucia’s House of Assembly Agrees To Income Tax Amendment (2) Act
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June 27th, 2019
The Government of Saint Lucia announced that its House of Assembly has agreed to the Income Tax Amendment (2) Act. This ensures that an international business company (IBC) would not give any benefit to companies that might violate OECD standards.
Poland Releases Guidance On Transfer Pricing Comparability Analysis
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June 27th, 2019
The Polish Ministry of Finance issued an explanatory note addressing transfer pricing comparability analyses. This rule is binding the taxpayer to be used when the analysis performed to test whether transactions between related parties conducted until the end of 2018 are in line with the arms-length principle.
US Pharmaceutical Giant Moves Its Headquarter To US from Ireland For Tax Purposes
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June 27th, 2019
AbbVie Inc. and Allergan plc. announce that the companies have entered into a definitive transaction agreement under which AbbVie, headquartered in US, has acquired Allergan on June 24, 2019. By that, one of US's pharmaceutical giants is coming back to the U.
UK Files A Challenge To European Court To Overturn State Aid Finding On Tax Anti-Abuse Rules
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June 26th, 2019
The U.K. is fighting an order by European Union antitrust chief Margrethe Vestager to claw back allegedly illegal tax breaks from multinationals, adding to the list of potential EU flashpoints ahead of Brexit. According to the tribunals website, Britain filed a challenge with the EU General Court.
Indonesia Proposed Amendments to Special Economic Zones Regime and Tax Cuts for Certain Sectors
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June 26th, 2019
Jakarta - Finance Minister of Indonesia, Sri Mulyani Indrawati, provides information to the media crew about the Government's plan to cut taxes in certain industrial sectors to attract investment.
Lowering Corporate Income Tax .
The Netherlands Consulting on New Tax Group Regime
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June 20th, 2019
The Netherlands Ministry of Finance has announced the launch of a public consultation on the design of a new corporate tax group (consolidation) regime to replace the current fiscal unity regime, which was recently amended by emergency repair measures as a result of compatibility issues with EU law.
Background .
U.S. Releases Regulations on Dividends Received Deduction Limitation
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June 20th, 2019
Final temporary regulations from the U.S. IRS and Treasury on the Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception were published in the U.S. Federal Register. The regulations were published and are effective on 18 June 2019, and also serve as the text of proposed regulations published the same date.
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