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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

Tax Relief

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.

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

Special features - June 2017

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

May 30 2017

Transforming tax – under pressure

Tax departments are feeling the heat. A tsunami of changes is causing them to rethink their purpose and review how they operate. Mark Body, director, tax transformation (financial services) at KPMG in the UK, considers how corporate tax leaders are adapting to the changes, and what the future is likely to hold for them and their teams.

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

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

Norway: Proposed interest limitation rules may impact inbound investments

Daniel Herde Trond Eivind Johnsen The Norwegian Ministry of Finance (MoF) has proposed changes to the interest limitation rules applying to group companies, possibly limiting the interest deductions for MNEs' inbound investments in Norway.

May 30 2017

Italy: New revision of the Italian Transfer pricing provisions on arm’s length principle

Barbara Scampuddu Gian Luca Nieddu On April 24 2017, the Italian Government introduced two important changes affecting the definition of the arm's-length principle for transfer pricing purposes. Art. 59 of Law Decree n. 50/2017, in fact, replaced the concept of "normal value" mentioned in Art. 110 paragraph 7 of the Italian Income Tax Code (ITC), fully aligning the wording of the domestic rule with the OECD arm's-length principle.

May 30 2017

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