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Is The Arm's Lenght Principle Still Valid After The Starbucks And Fiat Judgments?
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October 30th, 2019
Without doubt, the much-awaited judgments of the EU Court in Starbucks and Fiat have created an array of debates, from application of the concept of state aid to tax matters to redesign of transfer pricing concepts. Therefore, we bring to you three experts on the matter, Philip Baker, Hans van den Hurk and Steef Huibregtse, who will seek to answer some of these questions in a webinar and present their view on the judgement and what lies ahead for multinationals in Europe.
Irish Minister Donohoe Announces Government Approval For The Publication Of The Finance Bill 2019
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October 21st, 2019
The Irish Minister for Finance, Paschal Donohoe TD, announced Cabinet approval for the publication of the Finance Bill 2019 following the government meeting earlier last week.
Ireland's Finanance Bill makes further changes as required by the EU Anti-Tax Avoidance Directive (ATAD) and enhances Ireland’s position internationally with reforms in relation to transfer pricing in line with OECD guidelines.
Suite 2020: Business, Tax and Educational Technology Solutions
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October 18th, 2019
SUITE 2020 is a platform that combines different software’s features according to the specific needs of your business.
With the introduction of BEPS, tax and transfer pricing compliance is no longer straightforward and MNE’s are facing more and more challenges to manage tax risks in a growing number of jurisdictions.
Luxembourg 2020 Budget To Apply Automatic Expiration Of Pre-2015 Tax Rulings
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October 17th, 2019
The 2020 Budget Bill of Law provides filed by the parliament provides for the automatic expiration of pre-2015 tax rulings upon completion of the fiscal year 2019. The bill also provides that affected taxpayers may request a new ruling (valid for five years) under the current procedure.
Benelux Countries Sign Agreement To Combat Fiscal Fraud
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October 17th, 2019
Belgium, the Netherlands and Luxembourg have signed an agreement strengthening their cooperation in the fight against tax evasion. The attention will be focused on digitalisation to combat new forms of fraud and anticipate new phenomena in this area.
China's Fiscal Revenue Up 3.3% In January-September Period
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October 17th, 2019
China's fiscal revenue increased 3.3 percent year-on-year to around 15.07 trillion yuan (about $2.13 trillion) in the first nine months of 2019, official data showed on Oct 17. As the effect of tax and fee cuts continues to kick in, tax revenue has been on a falling streak since May, said Liu Jinyun, a senior official with the Ministry of Finance (MOF), at a press conference on Oct 17.
IRS Launches Proposed Rules Addressing Tax Consequences Of Discontinuation Of LIBOR And Other Interbank Offered Rates
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October 15th, 2019
The US Treasury Department and the US Internal Revenue Service (IRS) have issued proposed regulations REG-118784-18 to provide guidance on the tax consequences of the transition to the use of reference rates other than interbank offered rates (IBORs) in debt instruments and non-debt contracts (i.e.including interest rate swaps, cross-currency swaps and equity swaps).
The Tax Audit Process: Current And Future Standards
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October 14th, 2019
Tax audit is a process where tax authorities, based on their own fact finding, check taxes filled by taxpayers, examine accounting books and documentation, as well as review legal interpretations that are relevant for the purpose of making the final tax assessment. If an additional amount of tax or refund arises as compared with the taxpayers’ assessment, tax authorities issue a notice to the taxpayer.
Malaysia Sweetens Tax Incentives To Encourage Companies Set Up Hubs
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October 11th, 2019
Malaysia is expanding the scope of its Principal Hub (PH) program to allow more businesses to take advantage of tax incentives to base their country's local or global operations.
The key functions of principal hub companies include management of risks, decision-making, strategic business activities, trading, finance, management, and human resources, according to MIDA.
Become A Transfer Pricing Professional With The Online Study Trainer And E-Exam
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October 10th, 2019
Become a Transfer Pricing Professional with the online study trainer and e-exam: the most unique training package in the world!
The Transfer Pricing Professional online training consists of 2 online courses:.
Dutch Government Launches Consultation On Updated List Of Low-Tax Jurisdictions
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October 8th, 2019
The Dutch Ministry of Finance announced it has launched a public (Internet) consultation on the list of low-tax jurisdictions for 2020.
Background
Tax Technology - Choosing The Best Software Is Harder Than It Seems
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October 8th, 2019
Have you ever dreamed that the software would help you to perform your tax and transfer pricing tasks faster and more efficient? The dreams are coming true! The tasks can be automated and the transition is already happening, and not only among the corporates. In one of our previous articles, ‘ Tax administrations raise the playing field with technological solutions ’, TPA Global presented the increased usage of technology by tax administrations.
Guernsey Publishes Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
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October 3rd, 2019
A Briefing Note on the Mandatory Disclosure Rules on Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures (the Note) was published by the Guernsey Revenue Service.
Details of the notes .
French Government Issues Bill Pertaining To Corporate Taxation
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October 1st, 2019
The French government presented its draft Finance Law for 2020. It includes amendments regarding the scheduled reduction on corporate tax rates, which began in 2018 but was partially reversed for large companies for 2019.
Costa Rica Publishes List of Non-Cooperative Jurisdictions for Tax Purposes
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September 27th, 2019
The General Directorate of Taxation of the Costa Rican Ministry of Finance published a resolution on the list of non-cooperative jurisdictions for tax purposes No. DGT-R-55-2019.
Citeria for a jurisdiction to be included on the list .
India Slashes Corporate Tax Rates To Promote Investment
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September 24th, 2019
India has drastically reduced its corporate tax rates for domestic companies as part of a fiscal relief package designed to promote investment from both inside and outside the country.
Corporate tax rate reduction .
Experience of SAF-T in Europe (Starting Point of Digitalization)
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September 23rd, 2019
Touching down in Europe
With the current technological developments in the tax landscape, let’s not forget one of the starting points of the chain of technicalities. Initially agreed upon by all 38 OECD members of the Organisation for Economic Co-operation and Development (OECD), Standard Audit File for Tax (SAF-T) was one of the first tech-standard breakings into the European market.
The 2020 Dutch Budget And Tax Plan - Key Takeaways For Multinational Enterprises
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September 19th, 2019
Recently, the Dutch Budget for 2020 was presented, which includes the Tax Plan for 2020. The proposal aims to increase the perceived fairness of the Dutch corporate income tax system, whilst still keeping the Netherlands attractive as a place to do business.
EU Commission To Investigate 39 Belgium “Excess Profit” Tax Rulings For Potential State Aid Violations
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September 17th, 2019
The European Commission announced that it has opened 39 in-depth investigations to assess whether Belgian “excess profit” tax rulings granted to multinationals between 2005 and 2014 provided benefits that are contrary to EU State Aid rules.
Background .
Tax Authorities Are Powering Processes With Artificial Intelligence (AI)
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September 16th, 2019
Facing challenges
As we described in our recent articles ‘ Tax Administrations (TA) Raise The Playing Field With Technological Solutions ’ and ‘ Experience of SAF-T in Europe (Starting Point Of Digitalization) ' , tax authorities around the world are facing many challenges brought along with international requirements for full transparency, substance and consistency of data worldwide. Leveraging AI as a tool to enhance efficiency, useful outliers and data analytics for the tax administrations has also been a trend among countries.
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