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TPA Global Services Menu Card
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May 20th, 2019
We are pleased to provide you with our TPA Global Service Menu comprising the following standard service offerings:
Transfer pricing services
Norwegian Tribunal Adopts Profit Attribution Principles To Allocate Profit For PE
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May 16th, 2019
Norway's Tax Appeals Board was published decision concerning the allocation of costs to a permanent establishment in Norway. In particular, the decision addresses whether a deduction may be granted for the use of the parent company's employees and assets in determining taxable income of a permanent establishment.
Iceland Amends The CbC Reporting Requirements
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May 16th, 2019
Iceland's parliament approved amendments to Article 91 of the Income Tax Act, which includes the provisions for Iceland's Country-by-Country (CbC) reporting requirements. The amendments are based on feedback from the OECD.
Greens/EFA group in the EU Parliament Launches Tax Plans For 2019-2024
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May 16th, 2019
On 14 May 2019, the Greens/European Free Alliance (EFA) political group announced the launch of a 10-point plan for tax justice in the European Union, which will form part of its core demands for the coming legislative period in the European Parliament. The Greens/EFA Group has already been at the forefront of driving demands to combat excessive tax avoidance, tax evasion and money laundering in Europe.
France-Based Luxury Group Announces Settlement with Italy on PE and Transfer Pricing Issues
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May 14th, 2019
France-based luxury group Kering has reached a settlement with the Italian Revenue Agency concerning its Swiss subsidiary, Luxury Goods International S.A. (LGI), and concluded that the claims raised during the tax audit regard both the existence of a permanent establishment in Italy in the period 2011-2017 with the associated profits, and the transfer prices applied by LGI in the same period with its related party Guccio Gucci S.
EU Planning To Remove Bermuda, Aruba and Barbados From Tax Haven Blacklist
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May 14th, 2019
The European Union is planning to remove the British overseas territory of Bermuda, the Dutch Caribbean island of Aruba and Barbados from the bloc’s blacklist of tax havens at a meeting on May 17. The removals are due to the changing of their corporate law.
EU Seeks Consensus On Digital Tax
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May 9th, 2019
The EU Tax Commissioner highlighted that it is essential for the European Union that any global agreement on international corporate tax reform also fits the particular needs and situations of member states and the EU as a whole. This means shaping a solution that both respects the EU single market rules and benefits the single market.
Peru Issues New Guidance On General Anti-Avoidance Rule For Cross-Border Transactions
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May 9th, 2019
Peru has published a tax regulation clarifying the earlier General Anti Avoidance Rule (GAAR) regulation. The GAAR empowers the Peruvian tax administration to prevent tax avoidance, including tax avoidance involving cross-border transactions.
Dutch Court Allows Interest Deductions On A Hybrid Loan
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May 9th, 2019
The Dutch appellate published the decision on transfer pricing adjustments to hybrid loan. Based on the court decision, the Dutch appellate was allowing interest deductions on a hybrid intragroup debt instrument, rejecting the tax administration’s stance that the deductions were barred by transfer pricing and financial instrument characterization rules.
VAT Technology Solutions - Do You Feel That You Can Do More With VAT Data?
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May 9th, 2019
TPA Global and Cygnet Infotech, a multinational IT company based in India, are enlarging their scope of services to the European market for VAT solutions through a strategic alliance. Within this alliance, Cygnet Infotech will deliver the technology and TPA Global the VAT know-how.
Global Trade Management
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May 9th, 2019
In the ever changing and dynamic world of global trade, customs management and trade compliance management are mandatory prerequisites for a stable and secure supply chain. Customs and trade compliance management is the requirement for which companies must adhere to while importing and/or exporting goods and/or services across international borders while complying with all applicable laws and regulations.
Workshop For Corporates - "Fit For Future: A Refined Approach To Tax Risk Management"
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May 8th, 2019
During the past few years, the EU commission and many local governments have released a number of aggressive and uncoordinated initiatives to curb unwanted tax behaviour of multinationals, following the 2015 release of the BEPS Action Plans by the OECD/G20.
Consequently, MNEs are experiencing an increased exposure to tax controversies if they are not simultaneously in control of their Operating and Tax/Transfer Pricing models.
Ireland Is Forecasted To Lose €3bn If OECD Reforms Passed
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May 7th, 2019
During the conference held by Ministry of Finance and the International Monetary Fund (IMF) estimates that international tax reform could cost the State €2-€3bn in annual corporate tax revenues in the years ahead. The estimation relate to changes expected to emerge from an OECD reform process due to conclude next year.
Estonia Approves Money Laundering Risk Assessment Methodology
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May 7th, 2019
The Estonian AML/CFT Committee (the Anti-Money Laundering Government Committee), and the Countering the Financing of Terrorism Committee) approved a broad national risk assessment methodology to be introduced by summer 2020.
Background .
San Marino Amends Decree On CbC Reporting By Adding Penalties For Late CbC Reports
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May 2nd, 2019
San Marino has published Delegated Decree No. 68 of 25 April 2019, which provides for the amendment and ratification of Delegated Decree No.
Czech Finance Ministry To Introduce 7% DST To Tax Global Internet Giant
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May 2nd, 2019
The Czech Ministry of Finance announced it was planning to introduce a Digital Services Tax (DST). The Ministry is expected to present the proposed DST Bill (the Bill) by the end of May.
Australian Tax Authority Extends Data Matching To Cryptocurrency To Assist Tax Compliance
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May 2nd, 2019
The Australian Taxation Office (ATO), on April 30, 2019, announced that they were collecting trading records from designated service providers (DSPs) to ensure that cryptocurrency traders were presenting accurate income statements and not cutting out on taxes. Therefore, Australians trading in cryptocurrency may soon get a call from the Australian Taxation Office if its new data-matching program flags a problem.
The French Court Confirms That Google Ireland Has No PE In France
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April 30th, 2019
The Paris Administrative Court of Appeals confirmed a lower court judgment and struck down a reassessment of EUR 1.15 billion imposed by the French tax authorities on Google France which according to the authorities, constituted a permanent establishment in France for Google Ireland in relation to its Adwords services (search-based advertising).
India Publishes Notification On CbC Exchange Agreement With The U.S.
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April 30th, 2019
India published Notification No. 37/2019 from the Department of Revenue in an extraordinary version of the Official Gazette.
India and US Filling
Mexico Publishes Rules On Compliance of Anti Money Laundering Obligations
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April 25th, 2019
The Mexican Tax Administration Service (SAT) published the rules on compliance of anti money laundering obligations in its official gazette.
Anti-money laundering law obligations
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