Finland: Ministry of Finance issues a proposal to implement a corporate exit tax

20 November, 2019

On 7 November 2019, the Finnish Ministry of Finance published a proposal to introduce a corporate exit tax, largely based on the EU's Anti-Tax Avoidance Directive. The purpose of the EU exit tax is to prevent companies from avoiding tax on gains on

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US: Court of Appeals approves Tax Court’s decision in Transfer Pricing case

30 August, 2019

On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the

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Russia proposes Transfer Pricing and MAP-related changes

24 June, 2019

The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law

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Japan: Parliament enacts tax reform plans for 2019

02 April, 2019

On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance

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Japan proposes tax reform plans for 2019

31 December, 2018

On 14 December 2018, Japan's ruling coalition party has approved a package of tax reform proposals for 2019. The proposal includes amendments to Japan’s controlled foreign company (CFC), interest expense limitation, and general transfer pricing

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OECD issues a revised discussion draft on intangibles

01 August, 2013

For some time the OECD has been conducting a project on transfer pricing aspects of intangible assets including consideration of the definition and valuation of such assets.  A discussion draft was issued on 6 June 2012 and followed up by a

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