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The Cunningham column: China gets ready to lead tax world in 2016

China will be at the forefront of BEPS implementation in 2016, as president of the G20. Ralph Cunningham says it is a big opportunity for a non-OECD member to shape the international tax system.

December 15 2015

The Brockman brief: BEPS implementation: A holiday wish

Drafters of the new base erosion and profit shifting (BEPS) actions and precision watchmakers share a common wish; that their immeasurable efforts devoted to refining and juxtaposing complex parts result in an instrument that is respected and trusted around the world.

December 15 2015

BEPS Special

Matthew Gilleard introduces this exclusive, comprehensive insight into the work of the OECD in the area of countering tax base erosion and profit shifting (BEPS). Within these covers you will find out about the key messages delivered under each of the OECD’s 15 Actions, direct from the individuals responsible for putting each aspect of the project together.

December 15 2015

Argentina: Argentina and Mexico sign double tax treaty

Andrés Edelstein Ignacio Rodríguez Argentina and Mexico signed a new double tax treaty (DTT) on November 4 in Mexico City. The subsequent exchange of ratification instruments is expected to occur soon and will make the DTT effective as from January 1 following such ratification process.

December 15 2015

India’s TP regime takes steps towards global best practices

Since the introduction of Indian transfer pricing regulations in April 2001, transfer pricing has become the most important international tax issue for businesses operating in the country, says Vatika Bhatnagar of Airtel India’s global transfer pricing team.

December 15 2015

Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Petar Varbanov On March 26 2015, the Republic of Bulgaria and the United Kingdom of Great Britain and Northern Ireland signed a new Treaty for the Avoidance of Double Taxation (DTT) which will replace the DTT signed in 1987. The new treaty will introduce rules which differ considerably from the provisions now in force.

December 15 2015

Australia: Tax reform topics continue to dominate political scene in Australia

Chris Neil The debate regarding tax reform continues to dominate politics in Australia, with a number of alternative reforms being canvassed.

December 15 2015

Special features - December 2015 / January 2016

Read this month's special features for GCC - VAT and Intangibles

December 15 2015

Chile: Applicability of the beneficial owner concept for dividends in Chile

Germán Campos Kennett Fuenzalida Del Favero Double tax treaties (DTT) that follow the OECD's Model Tax Convention normally include the concept of 'beneficial owner' to determine the true owner of dividends, interests and royalties in order to apply special tax rates provided under such treaties.

December 15 2015

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Jean Marc Gagnon Alexandra Carbone In Amdocs Canadian Managed Services Inc. (ACMS), the Federal Court denied the Canada Revenue Agency's (CRA) request under section 231.7 of the Income Tax Act, Canada (Act) to compel ACMS to provide the CRA with documents and information requested in the course of a transfer pricing audit.

December 15 2015

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