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International tax news

Switzerland to exchange financial account information with 33 more countries for tax purposesAugust 15, 2019
Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . . 

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, NetherlandsAugust 14, 2019
The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . . 

Israeli tax authorities issue updated transfer pricing declaration Form 1385August 12, 2019
The Israeli tax authorities recently issued an updated Form 1385, which is a declaration regarding intercompany transactions with related parties, write Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher JH Consulting Ltd . . .


 IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangementsAugust 5, 2019
The US IRS will once again examine allocations between group members of employee . . .

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?August 2, 2019
Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting project has increased the scope for differences of opinion between tax authorities of different countries, writes Danny Beeton of Arendt & Medernach, Luxembourg . . .

  UAE country-by-country reporting rules publishedJuly 30, 2019
Saumitra R. Bhagwat and George German of Deloitte Middle East discuss new UAE Ministry of Finance transfer pricing guidance which sets out country-by-country reporting compliance obligations for multinational corporation groups. . .
New Zealand updates tax policy work planAugust 15, 2019
The New Zealand government on August 8 updated its tax policy work plan which reflects…

 Australia releases guidance on how the tax authority recovers a tax debt of a debtor located in a foreign country: Australian Taxation Office→August 15, 2019

Australian High Court confirms that tax office can use leaked documents including those obtained from law firms: Australian Taxation Office→August 14, 2019

 Google, Facebook, Amazon to testify at US trade hearing on French DST: Reuters→August 14, 2019 
 Finland budget offsets personal income tax reduction with hikes on fossil fuel, alcohol, tobacco: Aleksi Teivainen / Helsinki Times→August 14, 2019

US and Curacao negotiating country-by-country reporting exchange agreementAugust 14, 2019
The United States and Curacao are negotiating an agreement . . .

  Proposed IRS regs address cloud computing transactions, copyrighted article downloadsAugust 13, 2019
The US IRS on August 9 issued proposed regulations (REG-130700-14) concerning the income tax . . .

Armenia, Kyrgyzstan sign tax treaty: ARMENPRESS→August 12, 2019

 Uber generated USD 6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→August 12, 2019

CIAT database reflects progress made by 15 countries implementing BEPS recommendationsAugust 9, 2019
In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .
 Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLIAugust 9, 2019
The Australian government on August 9 published the synthesized texts of . . .

 BEPS multilateral tax treaty to enter into force for Ukraine August 8, 2019
Ukraine today deposited with the OECD legal documents ratifying . . .

 Albania joins Inclusive Framework on BEPS to address multinational tax issuesAugust 8, 2019
The OECD today announced that Albania . . .
 EESC supports new digital firm residual profit allocation using CCCTB formula with R&D cost as fourth factor; extending VAT to all digital services used by EU customers: European Economic and Social Committee→August 8, 2019 Cyprus Finance Minister drops proposal to increase corporate tax rate from 12.5 to 15 percent following business outcry: Bouli Hadjioannou / in-Cyprus→August 7, 2019

 UK must scrap DST for US to negotiate trade deal, US officials warn: Ben Riley-Smith / The Telegraph→August 6, 2019
 China’s planned Shanghai free trade zone to feature 15 percent income tax rate for qualified business: Xinhua→August 6, 2019

  UK investigating taxes paid by Candy Crush owner Activision Blizzar over royalties paid to Malta and Bermuda: Jon Ungoed-Thomas & Lucy Bacon / The Times→August 5, 2019

 Kenya Revenue Authority wins court fight over Cyprus-based oil pipeline company’s tax bill: Moses Michira / Standard Digital→August 5, 2019

 Saudi Arabia publishes English-language guide on making tax rulings requests: General Authority of Zakat & Tax→August 5, 2019


CIAT develops risk model for selection of transfer pricing audit cases in Ecuador: CIAT (in Spanish)→August 5, 2019 MLI amendments to Singapore-Luxembourg tax treaty enter into effectAugust 2, 2019
The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as . .  

Mexican government to propose increased tax on digital economy and e-commerce without adding a DST: Sharay Angulo & Anthony Esposito / Reuters→August 1, 2019
US MNEs reversing inversions, less likely to invert in the first place, because of 2017 tax changes: Richard Rubin & Jared S. Hopkins / WSJ→August 1, 2019

 Oman to delay 5 percent VAT until 2021: Avalara VATLive→July 31, 2019 Germany must recognize other EU States’ profit and loss transfer agreements for tax consolidation, Commission saysJuly 30, 2019
The EU Commission on July 25 decided to send a letter of formal notice to Germany for refusing to recognize profit and loss . . .
Denmark must adopt EU controlled foreign company tax rules, Commission saysJuly 30, 2019
The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

 EU Commission says Greece must allow deductions for foreign lossesJuly 30, 2019
The EU Commission has charged that Greece’s tax treatment of losses incurred . . 

Industry group to file complaint  with EU Commission alleging French digital tax is illegal State aid: Isabel Gottlieb / Bloomberg Tax→July 30, 2019


Lucas de Lima Carvalho 
“GLOBE and the Supranational ‘Nudges’ Affecting Domestic Tax Policy” 
Tax Notes International, Tax Analysts, July 29, 2019 (subscription service) 

Leopoldo Parada 
“How the Vodafone Magyarország Opinion Affects EU Debate on Turnover-Based Digital Taxes”
Tax Notes International, Tax Analysts, July 29, 2019 (subscription service)