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South Korea to hike taxes on large companies

The South Korean government and ruling Saenuri Party have produced a revised tax Bill targeting large companies, which is expected to raise tax revenue by KRW1.8 trillion ($887 million).

Matthew Gilleard, August 06 2012
Treaties of the week - August 7 2012

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement India Monaco August 1 2012

August 06 2012
UK updates CFC excluded territories exemption

The UK Treasury has revised the draft regulations for the excluded territories exemption (ETE) of the controlled foreign companies (CFC) regime.

Matthew Gilleard, August 06 2012
US lawmakers agree on how to speed up tax reform

US lawmakers have passed a Bill to expedite tax reform procedural issues in 2013. The Bill will provide a fast-track procedure for enacting tax reform, if the reform proposals meet certain requirements.

Matthew Gilleard, August 06 2012
OECD recognises demand for more guidance on guarantee fees and dispute resolution in transfer pricing

Joe Andrus, head of the OECD’s transfer pricing unit, has told TPWeek that guarantee fees and credit ratings are an important issue for the OECD but it is not possible to say when a formal project on the topic might start until the final intangibles report is released.

Sophie Ashley, August 05 2012
Dealing with the transfer pricing peculiarities in Brazil, India and Russia

Taxpayers are suffering as a result of the OECD’s lack of involvement with the world’s leading emerging economies when it comes to transfer pricing.

Jack Grocott, August 05 2012
IRS releases new foreign tax credit regulations

The Internal Revenue Service (IRS) and US Treasury Department recently released two sets of regulations addressing the foreign tax credit rules.

August 05 2012
The danger of non-arm’s-length management fees

Management fees present particular difficulties for taxpayers. Whenever an asset management service is performed by a resident of one jurisdiction for a recipient in another there are transfer pricing implications.

August 05 2012
What you have missed on ITR Premium

How to survive an Indian tax audit; why taxpayers have not welcomed the EC’s Quick Reaction Mechanism; and how AIG is still benefiting from a controversial US tax benefit were just three articles that appeared on ITR Premium last week.

August 05 2012
Eaton’s US Tax Court case could define obligations of parties to an APA

Mike Patton, of DLA Piper, explains why a pending US Tax Court case may help clarify the legal rights and obligations of the parties to an advance pricing agreement (APA).

August 05 2012

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