Global Tax News and Analysis
Treasury’s McDonald: Consider ‘Special Measures’ Separately from Transfer Pricing
By Rick Mitchell
Nov. 20 — A U.S. Treasury official said “special” measures aimed at addressing intangible assets in the context of base erosion and profit shifting should be considered separately from “traditional” treatment of intangibles under the arm’s-length standard.
Michael McDonald, a U.S. Treasury financial economist, spoke... [Read more of this article]
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EU: VAT considerations for transactions in shares representing immovable property
Stefan van Krimpen and Marcel Mãhlmann, Ernst & Young, Netherlands
This article discusses the VAT considerations regarding transactions involving shares that give the holder rights of ownership or possession over immovable property.
Based on the differences in legislation between EU Member States, the sale of shares can be within the scope of VAT... [Read more of this article]
Germany: Draft ordinance on permanent establishment profits
Andrew Miles, PwC, Tax & Legal Editorial Board
June 2013 saw the enactment of a revision to the Foreign Tax Act adopting the authorised ”OECD approach” (”AOA”) to the allocation of business profits to foreign permanent establishments. Essentially, this approach calls for the allocation of profits between the various parts of a legal entity... [Read more of this article]
Australia’s transfer pricing maze
Stuart J Edwards, Moore Stephens, Australia
Australia’s income tax legislation has long contained specific anti-avoidance legislation dealing with international tax avoidance schemes; one example of this is Division 13 of the Income Tax Assessment Act 1936 (ITAA 1936). Division 13 operated for all taxpayers until July 1, 2004 and for some until... [Read more of this article]
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