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US Inbound: New IRS APA report shows significant decrease in APA requests

Jim Fuller David Forst In Announcement 2017-3, 2017-15 I.R.B. 1, the US Internal Revenue Service (IRS) released its annual report on advance pricing agreements (APAs) for the 2016 calendar year. Fewer APAs were executed than in the prior year, and it took slightly more time to complete them. Of the 86 agreements executed in 2016, 37 were new APAs. This was a decrease from the 44 new APAs executed in 2015.

May 30 2017

Special features - June 2017

Read this month's special features on Technology, Mexico and China

May 30 2017

Germany: Finance Ministry issues guidance on the use of a brand name within a multinational group

Companies need to be prepared to answer tax questions on brand names and the application of the hypothetical arm's-length test as the appropriate transfer pricing method for trade mark fees.

May 30 2017

Greece: Administrative guidelines published on tax benefits of cross-border restructurings

Diana Tsourapa The Greek Independent Authority for Public Revenue (IAPR) has published Circular POL. 1057/2017 (the Circular), which sheds some light and provides the much anticipated administrative guidelines on the implementation of the Greek Income Tax Code (GITC) tax beneficial provisions, applicable to mergers, divisions, partial divisions, spin-offs and share-for-share exchanges (collectively the restructuring provisions). The provisions apply both in cases of Greek and EU cross-border restructurings.

May 30 2017

To arbitrate or not to arbitrate? The Mexican perspective

During the OECD Ministerial Council Meeting, which is to be held in Paris in the week beginning June 5 2017, Mexico will finally make public its stance on Mandatory Binding Arbitration, write Alejandro Torres Rivero and Andrea Obregón Widmer of Chevez, Ruiz, Zamarripa y Cia.

May 30 2017

New Zealand: Courts consider challenge to information requests issued at request of foreign tax authority

Brendan Brown Rhonda Gregory In a number of recent decisions, the New Zealand courts have considered a challenge to the validity of requests for information made by the New Zealand Inland Revenue at the request of South Korea's National Tax Service (Korea).

May 30 2017

Asia forum shows there is more to tax than BEPS

BEPS may have been first among the topics for discussion at International Tax Review’s Asia Tax Forum, but it was not the only subject on the list. As Ralph Cunningham reports, panellists and delegates were also keen to discuss issues such as anti-avoidance, dispute resolution and tax incentives in their own countries and elsewhere.

Ralph Cunningham, May 30 2017

Russia: Bilateral APAs offer new opportunities

The Russian transfer pricing rules (TP rules) enacted in 2012 provide the opportunity for taxpayers to conclude both unilateral and bilateral advance pricing agreements (APAs). However, no bilateral APAs have been concluded until now.

May 30 2017

Asia Tax Awards 2017

Twenty-eight different firms, individuals and companies shared the prizes at the Asia Tax Awards in Singapore.

May 30 2017

Indonesia: Will the amendments to the Income Tax Law simplify the rules?

Freddy Karyadi Nina Cornelia Santoso Since last year, the Indonesian government has planned to reform a number of tax policies, including an amendment to Law No. 7 of 1983 on Income Tax, which was last changed by Law No. 36 of 2008 (Income Tax Law).

May 30 2017

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