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New Zealand: New Zealand continues tax administration reform

Tim Stewart The New Zealand Government has continued its consultation on the simplification and modernisation of New Zealand's tax administration system by releasing the discussion document 'Making Tax Simpler – Towards a New Tax Administration Act' (discussion document (DD)).

March 09 2016

Poland: Poland introduces new R&D tax incentives

Monika Marta Dziedzic From January 1 2016, Polish tax resident companies can make an extra deduction from their tax base for expenditure incurred on research and development (R&D).

March 09 2016

US Outbound: US issues proposed CbCR regulations

Sean Foley Cameron Taheri On December 21 2015, the US Treasury Department and Internal Revenue Service (IRS) released proposed regulations that are designed to coordinate with the model country-by-country reporting (CbCR) template and instructions set forth in Action 13 of the OECD/G20 BEPS Project.

March 09 2016

Spain: Control of state aid in Canary Islands investments

Antonio Viñuela Llanos César Acosta Criado The Canary Islands economic and tax regime (REF), which we have mentioned in past collaborations in reference to the tax advantages of investing into, and from, the Canary Islands, has been recognised in the Spanish Constitution and by the European Union (EU), which has authorised the REF in accordance with Community Law, considering the tax incentives of the REF as state aid.

March 09 2016

US Inbound: US revises treaty model

Jim Fuller David Forst The US Treasury has released its revised 2016 Model Income Tax Treaty, which is the baseline text Treasury will use when it negotiates future tax treaties.

March 09 2016

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Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

The Supreme Court in Odfjell Rig (case Rt-2015-1360) concluded that the limited activities carried out onshore were not sufficient to create the taxable nexus to Norway that would be necessary for tax to apply to the income deriving from a bareboat charter.

Daniel M H Herde, March 09 2016

US to finalise CbCR rules by end of June

The US “fully expects” to have finalised its country-by-country reporting (CbCR) rules by June 30, according to Robert Stack, Treasury deputy assistant secretary for international tax affairs.

March 09 2016

US to finalise CbCR rules by July

The US will finalise its country-by-country reporting (CbCR) rules by July, according to Robert Stack, Treasury deputy assistant secretary for international tax affairs.

Joelle Jefferis, March 09 2016

A typical TP lifecycle and its effective implementation

Over the next three weeks, Ravi Lakdawala, transfer pricing lead at Bayer India, explores how taxpayers can implement a successful TP lifecycle from the planning stage to submitting documentation.

March 08 2016

The impact of BEPS Action 7 on operating models

Joost Vreeswijk and Ai-Leen Tan examine the impact that BEPS Action 7 will have on centralised operating models, and look at changes which multinationals should be considering to guard against exposure to the new rules.

March 08 2016

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