Government Releases New Transfer Pricing Measures to Attack Multinationals
On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The...
View Article“Cheeky” Maryland Rule, Requiring Mutuality In Arbitration Agreements, Not...
In most cases, if this blog mentions Concepcion, it means that a court has found a state statute or line of decisions is preempted by the FAA. A Maryland rule, however, recently ran the Concepcion...
View ArticleAppraisal Process Is Ripe For Revision
Appraisal has long been utilized as a tool for resolution of disputes over the amount of loss at issue in property insurance claims. Appraisal was once an amicable, prompt and independent process to...
View ArticleInternational Tax News - December 2013
CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund...
View ArticleIRS proposes changes to Competent Authority and APA procedures: comments...
The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and...
View ArticleFocus on Tax Controversy - Summer 2015
The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but...
View ArticleGlobal Tax News: Brazil opens consultation on how MAP provisions apply to DTT...
Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid...
View ArticleAdvance pricing agreements: a new era
There has been a significant amount of negative press recently concerning tax rulings and advance pricing agreements (APAs); negativity that has been fuelled by the European Commission's state aid...
View ArticleFalling Foul of Flying Freeholds
A mental image of a building sprouting wings and taking to the sky is one way to picture a flying freehold, but mention the phrase to most property lawyers and their hearts will sink. Discovering a...
View ArticleThe Mutual Agreement Procedure: A Taxpayers' Tool Reinvented
Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is...
View ArticleIreland's Revenue releases guidelines on requesting Mutual Agreement...
Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well...
View ArticleOECD releases reviews on BEPS Action 14
The OECD has released analyses of individual country efforts to improve dispute resolution mechanisms. Belgium, Canada, the Netherlands, Switzerland, the United Kingdom and the United States are the...
View ArticleJapan's National Tax Agency releases guidance on requesting Mutual Agreement...
The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD's Base erosion and profit shifting...
View ArticleNorway's Ministry of Finance releases guidance on seeking mutual agreement...
Norway's Ministry of Finance has released a guide for taxpayers on the mutual agreement procedure (MAP). The new guide, the first of its kind, contains general information on the use of MAP in...
View ArticleThe UK releases new guidance on Mutual Agreement Procedures
Her Majesty's Revenue and Customs (HMRC), the UK tax authority, has published revised guidance on the Mutual Agreement Procedure (MAP) in its International Manual (INTM) (at INTM 423000 –...
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