2018

Kenyan President Uhuru Kenyatta signed a new finance bill into law on Friday, cutting in half a new fuel tax that had led to public anger and strikes but stopping short of demands to scrap or delay it.

The top economic adviser to Brazilian presidential front-runner Jair Bolsonaro is ducking the limelight after an apparent dress-down from his boss over a tax plan.

Argentina is dropping plans to let corporations adjust their balance sheets for rampant inflation to reduce their taxable income. Under the old plan, companies could alter the value of their assetswhen prices rise by 100 percent over a three-year period, but the revised planwill force firms to use consumer prices instead of the higherwholesale price index in their income tax filings.

The IRS is considering giving more time and more guidance for multinationals looking to adjust the basis in the stock of some of their offshore assets under proposed transition rules for the one-time repatriation tax.

Revised transfer pricing guidelines are providing clarity to the Singapore tax community on the implementation of the amended transfer pricing legislation. The revisions include a penalty for noncompliancewith the mandatory transfer pricing documentation requirements, selective adoption of the OECD's BEPS Action Plan 13, among others.

New Zealand's Taxworking Groupwon't recommend a change to the country's 28% corporate tax ratewhen it makes its final report in February. New Zealand's government tasked the groupwith reviewing the country's entire tax system.

European Union analysis that large digital companies like Google Inc., Facebook Inc., and Amazon.com Inc. don't pay enough in tax is flawed, according to a study by Copenhagen Economics, an independent Danish-based consultancy.

Panasonic has announced that it is relocating its headquarters from the U.K. to the Netherlands, blaming concerns over Brexit-related uncertainty. But is there a different reason behind the move? This article explores the likelihood that Brexit concernswere the main reason for the relocation and posits another reason for the move.

The Hong Kong government enacted legislation in July 2018 to implement key actions arising from the OECD's BEPS agenda via its Inland Revenue Amendment No. 6 Ordinance 2018. The Ordinance codifies transfer pricing rules into Hong Kong's domestic tax law, introduces mandatory transfer pricing documentation requirements, expands the Advance Pricing Arrangement regime, and introduces a penalty regimewith potential civil and criminal sanctions. This article is a summary of the authors' key observations regarding the Ordinancewith a focus on the transfer pricing aspects.

France's promised business tax cutwill be delayed nine months according to its budget released Sept. 24.

Canadian manufacturerswant the government to offer fullwrite-offs for machinery and assets in a bid to keep upwith the changes included in U.S. tax reform.

Businesses should review existing stapled structures, set up to convert trading income into more favorably taxed passive income, as Australia's government moves a bill through parliament to crack down on the practice.

The IRS has announced that the advance pricing and mutual agreement program has reorganized to consolidate the program's resources to improve internal processes, resolve disputes, and increase taxpayer service.

In this article, the author discusses the growing use of cross-border audits, examining their connection to the push for transparency and how they operate bothwithin and outside the European Union. She addresses concerns about taxpayer secrecy, the potential benefits for both tax authorities and taxpayers, and discusses how taxpayers can prepare to face this new form of audit.

In this article, the authors discuss Alta Energy, inwhich the Tax Court of Canada held that a Luxembourg company's sale of shares in a Canadian shale development company to Chevron Inc.was exempt from capital gains tax as treaty-protected property under the Canada-Luxembourg treaty.

Too many EU tax treaties unfairly restrict developing countries' source taxing rights, and EU member states should reexamine and renegotiate those treaties to effectively lead on policy coherence for development, a new report says.

German Chancellor Angela Merkel told business leaders she is in favor of ending the reunification tax for all taxpayers, and that Germany can't "simply decouple" from theworld in thewake of U.S. corporate tax reform.

The European Commission's finding that McDonald's didn't receive illegal state aid from Luxembourg doesn't mean there is nothingwrongwith the EU tax system, EU Competition Commissioner Margrethe Vestager said.

Treasury may be trying to blunt some practitioner criticism about the potential breadth of the global intangible low-taxed income provision's pro rata share antiabuse rule, including its capacity to catch older transactions.

It's hard not to notice the newest employees at South Korea's Incheon International Airport. They're extremely polite, they can help passengers find their gates, and they're more than happy to take photoswith passengers. And each of them is fluent in four languages: Chinese, English, Japanese, and Korean.

Competition Commissioner Margrethe Vestager said in a September 24 speech in Vienna that she has "asked three experts to look into the implications of the future of digitization for competition policy," and theywill present their findings and recommendations next March.

The Court of Justice of the European Union has published the reference for a case (C-458/18) onwhether provisions under article 2 of the EU parent-subsidiary directive (2011/96/EU) should be interpreted to mean that the expression "companies incorporated under the law of the United Kingdom" applies to companies incorporated in Gibraltar.

Many of theworld's major financial centers are undermining other countries' tax laws and facilitating crime and corruptionwithout having toweather a listing on the EU's tax haven blacklist, according to new research.

An administrative appeals panel has reversed a decision by Brazil's Federal Tax Service (RFB),which denied awhirlpool subsidiary's deduction of an embezzlement loss on grounds that the unit's directorwas not awhirlpool employee.

A higher corporation tax ratewith a reduced rate for small businesses and greater transparency are among the proposals the Labour Partywants to introduce to make the U.K. tax system fairer.

Tax campaigners and academics have boycotted the KPMG "responsible tax" event this pastwednesday over concerns about the firm's past role in helping large multinational companies minimize their tax bills and the inclusion of a rightwing think-tank as a prominentspeaker. The eventwas billed as an "idea exchange"where a range of participants including politicians, academics, campaigners, and policymakerswould discuss the topic of "responsible tax".

Companies' record stock repurchases this year are causing profits to appear stronger and fueling the stock market's record run. A key driver in the surge of stock buybackswas last December's tax overhaul,which lowered companies' tax bills and freed up funds that many companies are using for share repurchases.

Peruvian President Martín Vizcarra on September 13 signed a legislative decree implementing the general antiavoidance rule introduced into Peruvian legislation on July 19, 2012.

A draft resolution recently released by European Union lawmakers contains an amendment thatwould let individual countries decide the percentage of a tax to be imposed on large digital companies.

Although proposed regs fail to completely resolve ambiguity surroundingwhether business interest limitations apply for purposes of calculating global intangible low-taxed income, until stated otherwise, they are arguably applicable.

The IRS has proposed (REG-130244-17) removing final regulations (T.D. 9790) under section 385 that provide minimum documentation requirements for some related-party interests in a corporation to be treated as indebtedness for federal tax purposes and has proposed conforming changes to other final regs to reflect the proposed removal of the documentation rules.

Proposed regulationswithdrawing the debt-equity documentation ruleswill help large corporations avoid spending $924 million in compliance costs over 10 years, but burdens continuewith the remaining anti-inversion, anti-earnings-stripping rules.

Three years after the Organization for Economic Cooperation and Development came outwith its base erosion and profit shifting plan, most tax incentives regimes for intellectual property development are now compliant, signifying that, as one OECD official said, "everybody is moving in the right direction."

Federal Reserve Board Chair Paul Volcker used to carry in his pocket a little slip of paperwith hourly constructionwageswritten on it.

In this article, the authors discuss the Google and Conversant cases,which illustrate the application of French dependent-agent permanent establishment case law to digital economy companies.

The book explores a topic that has been highly controversial in recent years: the use by multinational companies of "base erosion and profit-shifting" tax planning structures to reduce their tax liabilities in countrieswhere they conduct business, including theworld's lower-income developing countries. In this installment,which is the sixth and final chapter, the author considers the challenges of generating the politicalwill necessary to implement measures to curtail profit shifting as it currently affects lower-income countries. The most recent installment appeared in Tax Notes Int'l, July 16, 2018, p. 255.

The European Commission's proposal to tax digital serviceswould be interpreted as a tariff and likely provoke U.S. retaliation, according to a German economic analysis.The European Commission's proposal to tax digital serviceswould be interpreted as a tariff and likely provoke U.S. retaliation, according to a German economic analysis.

The Court of Justice of the European Union in EV v. Germany, C-685/16 (CJEU 2018), held that restrictions that Germany places on the deductibility of distributions of profits from shareholdings in non-member-state companies violate EU treaty provisions regarding the free movement of capital.

German restrictions on the deductibility of distributions of profits from shareholdings in nonmember-state companies violate EU treaty provisions on the free movement of capital, the Court of Justice of the European Union has held.

The IRS has issued guidance (Notice 2018-72) announcing that itwill amend the section 871(m) final regulations to delay the effective date of some rules in those final regs, further extending the phase-in period provided in Notice 2016-76 for specified provisions of the section 871(m) regs, and extending some of the transition rules described in Notice 2010-46.

The IRS has further delayed some dividend equivalent regulations following continued outcry from practitioners about implementing the complicated regime.

The Netherlandswants you to know that it is not a tax haven. But Menno Snel, the country's No. 2 finance official, grudgingly acknowledges that the Dutch have become experts at something else: aggressive tax planning.

China's government is grapplingwith an inconvenient truth: you can't cut taxes, boost spending and reduce the budget deficit all at the same time.

Prime Minister Justin Trudeau's government could make meaningful progress in addressing the nation's competitiveness challenges evenwithout taking the costly step of lowering the corporate tax rate, according to the head of the country's biggest business lobby.

U.S. corporations are required to pay a one-time tax on their offshore profits, but don't expect those stockpiled funds to come onshore quicklyÔøΩor ever. Companies repatriated $169.5 billion in the second quarter, according to data released Sept. 19 by the Commerce Department, up from $34.9 billion a year earlier.