ITR Search | International Tax Review

Shell still holding-up against Indian authorities in transfer pricing share dispute

Shell has won its most recent court battle with the Indian authorities in the Bombay High Court over its issuance of shares to a local entity, which the authorities have tried to claim additional income tax over.

Sophie Ashley, November 19 2014

Merck Group’s Frank Schoeneborn on patent boxes, people functions and profit splits

Frank Schoeneborn, head of operational transfer pricing at Merck Group, shares his views on BEPS progress, issues of confidentiality and the increasingly negative press transfer pricing is receiving.

November 19 2014

Deals of the week - November 17 2014

To add your deals to our weekly online deals table and monthly magazine deals table, email Joe Stanley-Smith on joseph.stanley-smith@euromoneyplc.com.

Joe Stanley-Smith, November 17 2014

Public registry of beneficial ownership in Denmark shows continuing trend

The Danish government, on November 7, announced plans to create a public registry of beneficial ownership.

Sophie Harding, November 17 2014

Greek Ministry of Finance issues templates and guidelines for advance pricing agreement negotiations

In an effort to provide taxpayers with an integrated procedural framework for the negotiation of advance pricing agreements (APAs), the Greek Ministry of Finance recently released template application forms for both preliminary consultations and formal negotiations, as well as additional guidelines on the overall APA procedure.

November 17 2014

German Federal Fiscal Court decides on treatment of hybrid entities under the German-US double taxation treaty

Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons

November 14 2014

UPDATE: Corporate tax exemption for profits made over Shanghai-Hong Kong Stock Connect

One business day before the opening of the Shanghai-Hong Kong Stock Connect, China’s Ministry of Finance formally announced that profits made on transactions over the connect will be temporarily exempt from capital gains tax. The introduction of the connect is the first time that individuals and small to medium investors will be able to access the Chinese stock market.

November 14 2014

Singapore and EU complete talks on FTA despite disagreements over investment protection

Singapore and the EU have concluded talks on a free trade agreement (EUSFTA) linking the two jurisdictions. The agreement was initialled in 2013, but negotiations on investment protection delayed its completion until October of this year.

November 14 2014

OECD announces three-part plan to open BEPS talks to more developing countries

The OECD has unveiled a plan to bring more developing countries into the discussions on base erosion and profit shifting. But tax justice campaigners have given it only a guarded welcome.

Ralph Cunningham, November 14 2014

EC says Netherlands tax deal with Starbucks constitutes state aid

The European Commission has released a preliminary view that an advance agreement struck between Starbucks and the Dutch government constitutes state aid.

Joe Stanley-Smith, November 14 2014

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