US: IRS appeals its tax court loss in the amazon transfer pricing case
On 29 September 2017, the Internal Revenue Service filed an appeal against March Tax Court ruling concerning Amazon’s cost-sharing agreement buy-in payment. The case is important because it is expected to provide fundamental guidance on the
See MoreU.S. signs agreements on the exchange of CbC reports with five countries
According to an IRS announcement on its website, it has signed separate agreements with the Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports on multinationals. Country-by-Country reporting data will be
See MoreUS: IRS issues guidance for tax credit for expanding research activities
The Internal Revenue Service has issued guidance to Large Business & International (LB&I) Division examiners regarding the examination of the credit for increasing research activities under IRC Section 41 (“Research Credit”) claimed by
See MoreJersey: Draft Budget 2018 Published
The Government published the Draft Budget 2018 on October 3, 2017. This budget constructs the package of measures agreed in the Medium Term Financial Plan (MTFP), combining savings, efficiencies and revenue raising measures to enable investment in
See MoreTransfer Pricing Brief: September 2017
Taiwan: Main corporate income tax rate: On 1 September 2017, Taiwan’s Ministry of Finance released tax reform proposals including to increase the corporate income tax (CIT) rate from 17% to 20%. The Proposal will become effective for taxable
See MoreAngola: Tax authority establishes transfer pricing unit
On September 25, 2017, the Ministry of Finance issued the order no. 678/17 establishing the Transfer Pricing Unit (TPU) to ensure and control compliance with the requirement to submit transfer pricing documents. In addition to ensuring and
See MoreWorld Tax Brief: September 2017
Sri Lanka Main corporate tax rates: The Parliament passed the new income tax law on 7 September 2017. Beginning from 1 April 2018, the corporate income tax (CIT) rates will be revised to a three-tier structure consisting of a lower rate of 14%,
See MoreFrance: Draft finance bill for 2018 released
The government of France released the draft Finance Bill for 2018 on 27 September 2017. The main changes outlined in the draft Bill are as follows: Decrease of the French corporate income tax rate Elimination of the 3% tax on dividend
See MoreCroatia: EU Council gives approval to increase VAT registration threshold
The Council executing a Decision no. 2017/1768 of 25 September 2017 in the Official Gazette on September 28, 2017 for allowing Croatia to announce a special measure derogating from Article 287 of Directive 2006/112/EC on the usual system of value
See MoreUnited States: IRS issues draft advance pricing agreement (APA) template for public comment
The US Internal Revenue Service (IRS) has recently published on its web page that the IRS’s Advance Pricing and Mutual Agreement Program (APMA) is soliciting comments on a proposed revision to the template for advance pricing agreements (APAs).
See MoreIreland: New Guidance on DWT
On 26 September 2017, Irish Revenue published guidance on dividend withholding tax (DWT) with some exceptions and stated that resident companies must withhold tax on dividend payments and other distributions that they make. Qualifying Irish
See MoreUAE: Excise tax on tobacco, energy and soft drinks enters into effect
The Ministry of Finance was published the implementing regulations to the Excise Tax Law. This Excise Tax Law regarding production of excise goods in the UAE, import of excise goods in the UAE, release of excise goods from a designated zone and
See MoreDominican Republic: DGII publishes the sixth version of the transfer pricing information
Recently, the Dominican Republic Tax Authorities (DGII) published the 6th version of the transfer pricing information return (DIOR) through its virtual platform. The content of the form has been simplified to guarantee the accuracy and organization
See MoreSwitzerland: Ordinance on exchange of CbC reports adopted
On 29 September 2017, Swiss Federal Council adopted an ordinance on the international automatic exchange of country-by-country reports on multinational firms. The exchange of country-by-country reports between Switzerland and its partner states
See MoreJapan publishes guidance for taxpayers on the MAPs
Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute
See MoreOECD: Forum on Tax Administration meets to discuss tax priorities
The Forum on Tax Administration (FTA) discussed tax issues at its plenary meeting on 27 to 29 September 2017. The FTA includes the Tax Commissioners of fifty tax administrations covering industrialized and emerging economies including the OECD and
See MoreOECD: Peer review reports on dispute resolution mechanisms
On 26 September 2017 the OECD released six peer review reports evaluating efforts to improve dispute resolution mechanisms. The reports relate to implementation of measures by Belgium, Canada, Netherlands, Switzerland, the UK and the US. A document
See MoreUS: Donald Trump plans to reduce tax burden for corporations and individuals
President Donald Trump proposed on 27 September 2017 the biggest U.S. tax overhaul in three decades. The proposals come in a “framework” for tax reform with the following changes. Individual measures: Seven existing tax brackets collapsed to
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