International Tax News, Transfer Pricing News – MNE Tax
网页Israeli Courts Again Side with Taxpayer in Transfer Pricing Business Restructuring Ruling. June 14, 2022. In a recent decision by the Israeli District Court in Tel Aviv, the court rejected the Israeli tax authorities’ (ITA) argument that a post-acquisition amendment to the appellant business model necessarily implies a sale of business.
United States - MNE Tax
网页2022年4月12日 · Kyle Pomerleau, American Enterprise Institute, warns that while the Biden Administration’s recently released 2023 budget—which includes additional reforms to the tax treatment of multinational corporations—is intended to further align the U.S. tax code with the OECD’s Pillar Two model rules and enhance the competitiveness of U.S. multinational corporations, they actually could leave U ...
Taxing offshore indirect transfers, the Platform’s new toolkit - MNE …
网页2020年6月10日 · By Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland. On 4 June, the Platform for Collaboration on Tax, a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG), released its new toolkit concerning the taxation of offshore indirect transfers. Indeed, as developing countries must cushion COVID-19’s ...
Multinational
网页Kyle Pomerleau, American Enterprise Institute, warns that while the Biden Administration’s recently released 2023 budget—which includes additional reforms to the tax treatment of multinational corporations—is intended to further align the U.S. tax code with the OECD’s Pillar Two model rules and enhance the competitiveness of U.S. multinational corporations, they actually could leave U ...
Transfer Pricing - MNE Tax
网页2022年5月17日 · July 7, 2022. In a bid to curb profit shifting, Kenya is increasing its transfer pricing documentation requirements. The recently published Kenya Finance Bill seeks to have the ultimate parent entity of a multinational enterprise group or a constituent entity of a multinational enterprise group (MNE’s), which is a tax resident in Kenya, file ...
Europe - MNE Tax
网页2022年4月20日 · Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation. June 28, 2022. Late 2021, Finland implemented a regulation concerning taxation of reverse hybrid arrangements included in article 9a of ATAD2 directive (Council directive (EU) 2017/952 amending Directive 2016/1164). The new rules have been implemented in Section 8a of ...
MNE Tax–MNE Tax
网页2021年6月23日 · MNE Tax joins CrossBorder Solutions! June 23, 2021. MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .
OECD develops exchange framework for digital platform tax …
网页2021年6月22日 · By Doug Connolly, MNE Tax. The OECD sets out in a June 22 report a multilateral competent authority agreement for the automatic exchange of information relating to income derived by sellers of certain services through digital platforms such as Uber and Airbnb.. The report also includes an optional extension of the scope of such reporting to cover additional types of services and sales beyond ...
China simplifies procedure for claiming tax treaty benefits
网页2019年11月17日 · China’s State Taxation Administration on 14 October published “Administrative Measures for Non-resident Taxpayers Claiming Tax Treaty Benefits” [Announcement (2019) No. 35]. Announcement (2019) No. 35 will become effective from 1 January 2020, and will replace existing Announcement (2015) No. 60. The new regulation simplifies filing ...
Financial transactions tax–MNE Tax
网页2020年4月22日 · Francesca Amaddeo a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, analyzes a long-awaited decision of the European Court of Justice, released on April 30, that concludes Italy’s financial transaction tax on derivatives of equity transactions is compatible with EU law . . .
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