Category: Tax Dispute
Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties
Switzerland’s Federal Council, at its November 11 meeting, approved protocols to its existing bilateral tax treaties with Liechtenstein, Malta, and Cyprus. ... - Continue reading
Croatia to initiate tax treaty negotiations with the United States
The government of the Republic of Croatia, on September 30, adopted a decision to initiate proceedings to conclude a convention with the United States on the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income. ... - Continue reading
OECD assesses Cayman’s process to resolve double-taxation disputes
OECD examines Cayman Islands' implementation of BEPS Action 14. ... - Continue reading
Netherlands announces new policies for resolving cross-border tax disputes
The government has implemented new legislations in order to reform treatment of offshore tax disputes. ... - Continue reading
OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden
Reports on offshore disputes have been published by the OECD. ... - Continue reading
France wants a solution for US dispute on digital tax within 15 days
Can a fortnight provide a solution for the tax dispute between the USA and France? This should be made aware in the days to come, but right now let's find out the details to this situation. ... - Continue reading
OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes
Taxpayers are invited to submit comments on their experiences by December 16 through filling out a taxpayer input questionnaire. ... - Continue reading
OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals
The OECD on November 15 published more than 300 comment letters that respond to its request for feedback on the Secretariat’s proposal for a “unified approach” to pillar one. ... - Continue reading
RenTech’s Billion-Dollar Tax Cloud Darkens After IRS Ruling
A little-noticed decision by the Internal Revenue Service’s appeals unit may spell trouble for legendary investor Jim Simons, who’s embroiled in a multibillion-dollar tax dispute with the agency. ... - Continue reading
Unresolved cross-border tax disputes continue to rise, OECD stats show
Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax disputes, overall mutual agreement proceedure (MAP) inventory continues to increase, OECD statistics released today revealed. ... - Continue reading
US appeals court sides with Amazon in $1.5 billion transfer pricing dispute
A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
BEPS multilateral tax treaty to enter into force for Ukraine
Ukraine today deposited with the OECD legal documents ratifying a multilateral tax treaty called the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
Mauritius leaks: Big firms leveraging legal loopholes to save taxes can cost developing countries $100 bn every year
Proposals made by Nirmala Sitharaman at G20 Summit could alter the stasis between large corporations and tax havens. ... - Continue reading
Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation
A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading
OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia
The OECD on July 5 requested taxpayer feedback on the tax treaty dispute resolution process in Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco,and Tunisia. ... - Continue reading
Tax disputes reach record length
The length of time taken to settle tax investigations into large businesses has increased by 10% to a record 43 months as of March 2019 ... - Continue reading
Cook Islands joins coalition to fight tax avoidance
The Cook Islands has joined a coalition of countries aimed at fighting tax avoidance and easing cross-border tax dispute resolution. The country has joined 124 other countries in the Inclusive Framework on base erosion and profit shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) announced earlier this month…. – Continue reading
BEPS Project Has Triggered Near-Global Tax Reform: OECD
The OECD has committed to providing proposals to fix the taxation of the digital economy by 2020, in an update to G20 leaders on international efforts to mitigate base erosion and profit shifting (BEPS). In the newly released Second Annual Progress Report of the OECD/G20 Inclusive Framework on BEPS, the… – Continue reading
More Information… More Intense Transfer Pricing Disputes?
The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the… – Continue reading
Transfer pricing disputes: Interest payout relief coming for MNCs
CBDT issues draft notification on interest computation NEW DELHI, JUNE 20 The Central Board of Direct Taxes (CBDT) proposes to provide a relief to MNCs on the interest payable by them on the untaxed profits stashed abroad, requiring to be repatriated back to India under the transfer pricing regime. It… – Continue reading
Australia Adds To Diverted Profits Tax Guidance
The Australian Tax Office on February 7 released draft Practical Compliance Guideline 2018/D2 on the operation of Australia’s Diverted Profits Tax for consultation. In the 2016-17 Budget, the Government announced that it would introduce a diverted profits tax (DPT), intended to ensure that the tax paid by significant global entities… – Continue reading
Swiss Taxpayer Wins US Tax Treaty Refund Dispute
The United States District Court for the District of Columbia on January 31 ruled in favor of Starr International Company in a case concerning an erroneous refund paid to the taxpayer, which the IRS sought to reclaim. In 2011, the IRS erroneously issued a USD21m refund to Starr International Company,… – Continue reading
OECD statistics show 20% increase in outstanding tax treaty disputes involving UK
The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading
Ten important Canadian Tax compliance considerations for new Canadians
The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on… – Continue reading
Davis Tax Committee report
The Davis Tax Committee (the Committee) released a further report on “Tax Administration” on 13 November 2017 as part of the final six reports that were deliverable by the Committee. The report has five chapters covering: Governance of the South African Revenue Service Base Erosion and Profit Shifting (BEPS) Treatment… – Continue reading
EU Framework for resolving double tax disputes
The EU Economic and Financial Affairs Council has adopted a Directive to create a new system to resolve double taxation disputes between EU Member States. This measure will afford taxpayers a transparent process with clear deadlines applicable to tax authorities involved to resolve cross-border double tax disputes within the EU…. – Continue reading
GRA, Vodafone Ghana tax dispute: Commissioner-General refuses waiver of 30% payment
In a dramatic turn of events in the Ghana Revenue Authority (GRA) and Vodafone Ghana tax dispute before court, the Acting Commissioner-General of the GRA has refused to grant a waiver of the payment of 30 per cent of the value of tax in contention. In a letter to Vodafone… – Continue reading
EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes
European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding… – Continue reading
BHP willing to head to court against ATO tax bill
BHP is willing to head to court to fight the Australian Taxation Office on a more than $1 billion tax bill over its Singapore marketing hub. The world’s largest miner has continually defended its Singapore marketing hub, where it is accused of routing profits, and says it is confident of… – Continue reading
UK diverted profits tax: What companies should do next
ANALYSIS: Companies are likely to receive a preliminary notice under the new diverted profits tax (DPT) regime between now and the end of 2017. They should treat the issue of a notice as potential litigation and should immediately involve their legal advisers. For many companies the time limit for the… – Continue reading
