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  • EU Lays Down Law on Tax Deals as Apple Probe Continues

    Bloomberg

    by Gaspard Sebag

    The European Union, locked in a tax battle with the likes of Apple Inc. and McDonald's Corp., laid down the law in its bid to rein in governments that woo multinationals with special deals allowing them to reduce their fiscal liability by booking profits abroad.
    For DTR story, go here Subscription Required
    By Sebag, Gaspard, posted on Thursday May 19, 2016
  • Debt-Equity Regs' Contemporaneous Documentation Rules in Context

    Tax Analysts

    by Amy S. Elliott
    Are the documentation requirements in the proposed section 385 debt or equity regulations strict in comparison to those of other countries or do they only seem onerous because U.S. multinationals have historically been lax in achieving the gold standard of contemporaneous documentation?
    To read more go here Subscription Required
    By Elliott, Amy S, posted on Wednesday May 25, 2016
  • Senators Continue to Argue Against EU State Aid Investigations

    Tax Analysts

    by Kat Lucero
    A bipartisan group of Senate taxwriters urged the Treasury Department on May 23 to put pressure on the European Commission to keep it from issuing tax regulations that would single out U.S. multinational companies in ongoing state aid investigations.
    To read more go here Subscription Required

    By Lucero, Kat , posted on Wednesday May 25, 2016
  • European Commission Explains Review of Tax Rulings

    Tax Analysts

    by William Hoke
    After weeks of defending itself against criticisms for state aid cases targeting rulings granted to U.S. multinationals, the European Commission has published a detailed paper explaining the criteria for determining whether benefits provided by a member state are in violation of EU law.
    To read more go here Subscription Required
    By Hoke, William , posted on Wednesday May 25, 2016
  • Countering Base Erosion Is Impossible Within Current Framework, Panel Says

    Tax Analysts

    by Ryan Finley
    The basic principles of the current international tax regime are fatally flawed and antiavoidance measures that fall short of a complete overhaul are doomed to fail, according to a panel of academics, reform advocates, and other experts.
    To read more go here Subscription Required
    By Finley, Ryan, posted on Wednesday May 25, 2016
  • Incentives Key in Developing Countries' Tax Reform Efforts, OEDC Official Says

    Tax Analysts

    by Alexander Lewis
    In the fight against harmful tax competition, the number one issue for developing countries is tax incentives, said Grace Perez-Navarro, deputy director of the OECD's Centre for Tax Policy and Administration.
    To read more go here Subscription Required

    By Lewis, Alexander , posted on Wednesday May 25, 2016
  • Adobe Subsidiary Not a PE, Delhi High Court Rules

    Tax Analysts

    by Alexander Lewis
    The Delhi High Court on May 16 ruled in Adobe Systems Inc. vs. ADIT that a U.S.-based software company's Indian subsidiary is not a permanent establishment under the India-U.S. income tax treaty.
    For the WWTD story, go here Subscription Required
    By Lewis, Alexander, posted on Friday May 20, 2016
  • TAXE II Committee Members Optimistic About EU Tax Base Harmonization

    by Ryan Finley
    The string of revelations and scandals that have made taxation a major political issue in Europe have provided an "incredible opportunity" for member states to reach consensus on a common consolidated corporate tax base, according to Alain Lamassoure, chair of the TAXE II Committee.
    For the WWTD story, go here. (subscription required)
    By Finley, Ryan, posted on Friday May 20, 2016
  • News Analysis: What's So Bad About BEPS?

    by Mindy Herzfeld

    The OECD's base erosion and profit-shifting project is based in large part on the premise that those practices are harmful because they deprive governments of needed revenues. Few have disputed this assumption, and even the corporate tax community has not defended base erosion practices. 

    Among the few who are willing to challenge this basic assumption is Daniel Mitchell of the Cato Institute, whose blog defends international tax competition.

    For the TNI article, go here. (subscription required)

    By Herzfeld, Mindy, posted on Monday May 23, 2016
  • News Analysis: Why the New Model Treaty?

    by Lee A. Sheppard
    Before we meditate about who might actually sign the new U.S. model treaty 2016 TNT 32-29: Model Tax Treaties, let's look for a ray of hope in men's fashion.
    For the Tax Notes article, go here. (subscription required)
    By Sheppard, Lee A., posted on Monday May 23, 2016