ITR Search | International Tax Review

Bosnia and Herzegovina: Instruction on indirect tax exemption under Instrument for Pre-Accession Assistance Programme II

Igor Vujasinovic On November 11 2015, a new Instruction issued by the director of the Indirect Tax Authority of Bosnia and Herzegovina entered into force. The Instruction was published in the Official Gazette of Bosnia and Herzegovina on November 30 2015.

March 30 2016

Cyprus: Treaty analysis: Cyprus – Ethiopia double tax agreement

Christiana Nicolaou Cyprus is continuing to develop its network of double taxation treaties (DTTs) through the signing of a new DTT with the Federal Democratic Republic of Ethiopia, on December 30 2015. The treaty is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital, and it was published with the official Cyprus Government Gazette on January 18 2016.

March 30 2016

US Inbound: US Tax Court upholds IRS authority to make aggregated TP adjustments

Jim Fuller David Forst Guidant v Commissioner, 146 TC No 5 (2016) is a transfer pricing case addressing the IRS's ability to make a single adjustment for a US affiliated group where different US members of the group engaged in intercompany transactions and different types of transactions occurred. In the case, six related US entities variously engaged in sales, licensing and services transactions with a large number of foreign manufacturing and distribution affiliates.

March 30 2016

Relief from the bizarre taxes; Part two

Anyone who was around in the Middle Ages can attest that soap deserved an exemption as an essential good. Especially when considering number 3 in the list Some of the strange taxes from history make modern taxes seem almost desirable. Tax avoidance may be hitting today's headlines, but trying to avoid tax has existed as long as tax itself.

March 30 2016

The Brockman brief: The (post-BEPS) tax function of tomorrow

The evolution of international taxation, driven by the OECD’s BEPS Actions, is eliciting new ways of thinking about the effective management of an internal tax function.

March 30 2016

Canada: Tax Court of Canada: Foreign rectification orders not binding on CRA unless properly recognised by Canadian courts

Francois Auger Julia Qian Wang In Canadian Forest Navigation Co Ltd (CFN), the Tax Court of Canada (TCC) determined as a question of law that the Canada Revenue Agency (CRA) is not bound by foreign rectification orders and is not precluded from taking a position contrary to such orders.

March 30 2016

How patent boxes became the new normal

Since October 2015, authorities have been reacting to the outcome of the BEPS Project. The implementation of new legislation and adaption of existing regulations to match the new OECD guidelines has already begun to impact multinationals worldwide. The undeniable headline change has been a broad move to implement country-by-country reporting (CbCR); however the other policy that stands out from the crowd is in the area of patent boxes, as Joelle Jefferis explains.

March 30 2016

Deals of the month

See who has done the tax work on this month’s biggest deals

March 30 2016

Australia: Capital gains tax withholding

Eddie Ahn On February 25 2016, the draft legislation introducing a new foreign resident capital gains tax (CGT) withholding regime received Royal Assent after being passed by the Australian Parliament. These rules take effect from July 1 2016 and impose a withholding tax obligation on purchasers of certain Australian real estate related assets.

March 30 2016

Brazil: Amendments to interest on net equity not passed

Alvaro Pereira Mark Conomy On March 10 2016, the Brazilian Congress published Act No 5 of 2016, which provided that Provisional Measure 694 (PM 694/2015) expired on March 8 2016 and would not be converted into law. PM 694/2015 was released on September 30 2015, and was principally concerned with amendments to the calculation basis and withholding tax rates applicable to interest on net equity payments (INE).

March 30 2016

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