This content is from: Sponsored Changes to Chilean TP rules on related parties Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC. By Gregorio Martínez & PwC Chile May 29 2018
This content is from: United States The irresistible rise of Andersen Tax Josh White speaks to Andersen Global Chairman and CEO Mark Vorsatz about the firm’s ambitions and the long shadow cast by its predecessor. By Josh White May 29 2018
This content is from: Kenya Why tax avoidance by multinationals and illicit financial flows are the same thing Logan Wort, executive secretary of the African Tax Administration Forum (ATAF), argues that harmful tax practices can be eliminated by addressing this specific component of illicit financial flows. By Contributed May 29 2018
This content is from: Sponsored BEPS Actions 8 to 10: National interpretations of TP guidance Annika Lindström and Maria Andersson of KPMG discuss how BEPS Actions 8 to 10 are being interpreted in relation to transfer pricing (TP) in Sweden. By ITR Correspondent May 29 2018
This content is from: Sponsored SPACs: A new financial instrument available in Mexico During 2017 and 2018 the Mexican Stock Exchange witnessed the placement of securities issued by the first two Mexican special purpose acquisition companies (SPACs). Alberto Alvarez and Moisés Gutiérrez of Chevez, Ruiz... By Alberto Álvarez Flores & Chevez Ruiz Zamarripa & Moisés Gutiérrez Morales May 29 2018
This content is from: Sponsored TP aspects of business restructuring: A Dutch case Rachit Agarwal and Jian-Cheng Ku of DLA Piper discuss the transfer pricing (TP) aspects of a business restructuring within a multinational enterprise (MNE) group, through reference to a recent high-stakes Dutch court ... By DLA Piper Netherlands & Jian-Cheng Ku May 29 2018
This content is from: Australia Asia Tax Awards 2018 Firms, individuals and companies across the Asia-Pacific region shared prizes at the Asia Tax Awards in Singapore on May 3 2018. By Anjana Haines May 29 2018
This content is from: United States Global interest limitation rule: A matter of time? The US, EU member states and other countries have proposed and/or adopted a limitation rule for the deduction of interest by a corporate taxpayer. Will the OECD try to provide worldwide guidance for interest limitatio... May 29 2018
This content is from: Sponsored South Africa: How the MLI will impact on investment structures involving Mauritius Those investing into South African companies via Mauritius need to evaluate whether they can defend their structures against any future PPT related challenges that may arise. By ITR Correspondent May 29 2018
This content is from: Mauritius SNC-Lavalin defends its tax affairs after being named in West Africa leaks Canadian engineering company SNC-Lavalin has defended its use of a Mauritian company, telling International Tax Review that it structures its business in a tax-efficient manner that’s compliant with the law. By Josh White May 25 2018
This content is from: United States MNEs get easy ride under US repatriation and GILTI regimes as US expats pick up the bill Although the 2017 US Tax Cuts and Job Act (TCJA) aimed to cut taxes for all Americans, individual US shareholders of controlled foreign corporations (CFCs) living outside the US (expats) are being discriminated agains... By Contributed May 22 2018
This content is from: New Zealand MNEs prepare for BEPS bill after New Zealand budget’s limited tax proposals New Zealand Finance Minister Grant Robertson refrained from proposing many corporate tax proposals in his 2018 budget, leaving the tough measures against MNEs to the BEPS bill. By Anjana Haines May 21 2018
This content is from: European Union Netflix ‘disappointed’ with EU country of origin state aid ruling Netflix has told International Tax Review that it is "disappointed" with the EU General Court's ruling in the German state aid case concerning the country of origin principle. The company said the judgment leaves serv... By Josh White May 17 2018
This content is from: Luxembourg LuxLeaks verdict sets ‘strong precedent’, says acquitted ex-PwC whistleblower Antoine D... Luxembourg’s Court of Appeal has cleared whistleblower Antoine Deltour of stealing PwC documents in the LuxLeaks scandal. Deltour told International Tax Review the ruling sets a strong precedent for tax justice. By Josh White May 15 2018
This content is from: Uruguay Amendments to Uruguay’s Free Zones Act Uruguay’s parliament has amended several provisions of the Free Zones Act, impacting tax benefits. Guzmán Ramírez of Bergstein Abogados provides a summary of the main amendments introduced in such an act. By Contributed May 14 2018
This content is from: Australia MNEs hit by Australia’s R&D tax proposals in 2018 budget Companies may begin to look elsewhere to invest in research and development after Australia’s Treasurer Scott Morrison said he will be cracking down on the use of R&D tax incentives. By Anjana Haines May 11 2018
This content is from: European Union Will the ATAD drive up financing costs? Concern is growing among Sweden’s financial services sector about how the EU Anti-Tax Avoidance Directive (ATAD) will affect financing costs, but a tax director at a private equity fund warns that these issues also ap... By Josh White May 11 2018
This content is from: European Union Companies see no gain in splitting Big 4 tax and audit functions UK proposals to separate tax and audit functions within the Big 4 accounting firms will not make a difference to the market or the way businesses choose their advisers, a tax director at a major fintech company has to... By Josh White May 10 2018
This content is from: United States Coca-Cola optimistic ahead of IRS dispute ruling As the trial nears its end, Coca-Cola is confident of its chances of winning the high-stakes case against the IRS, according to the company’s 10k filing. The IRS is demanding $3.3 billion in back taxes, plus interest. By Josh White May 04 2018
This content is from: European Union Germany’s new finance minister distances himself from EU digital turnover tax Germany’s new finance minister seems to have arced in terms of his political progression, starting out as a left-leaning gymnast in the 1980s and evolving into a mainstream politician whose views largely mirror those ... By Michael Scaturro May 02 2018
This content is from: European Union UK to force overseas territories to set up beneficial ownership registers The UK parliament has voted to force some of the world’s most-used tax havens to set up registers of beneficial ownership. This will necessitate tax planning changes for many companies and individuals. By Joe Stanley-Smith May 01 2018