International

Friday, 04 September 2015

Advance pricing agreements: IRS issues updated procedures

Written by Thomson Reuters

The IRS recently issued guidance on the process for requesting and obtaining advance pricing agreements (APAs). In Revenue Procedure 2015-41, the IRS also provides guidance on the administration of executed APAs. The IRS guidance is being issued concurrently with procedures and guidance on the process for requesting assistance from the U.S...

Published in International
Tuesday, 04 August 2015

U.K. plans to cut corporate tax rate to 18% by 2020

Written by Thomson Reuters

The United Kingdom’s Summer Budget 2015 disclosed plans to trim the country’s main corporate tax rate in two steps. The rate is scheduled to be cut to 19% in 2017 and to 18% in 2020 from the current 20%. The U.K...

Published in International
Tuesday, 04 August 2015

MNEs seek change to BEPS transfer pricing proposals

Written by Thomson Reuters

A group of multinational enterprises (MNEs) in the United States and abroad has asked the U.S. Treasury to “significantly change” certain transfer pricing guidance arising from the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. The group says it believes that the proposals should be debated by participating countries as “non-arm’s length special measures” that should only be applied prospectively, rather than “slipped into” the international tax system “under the guise that they are consistent with the long-standing arm’s length standard...

Published in International

The European Parliament voted in favor of a "say-on-pay" measure to increase shareholders' rights, along with another measure that would require multinationals to disclose the amount of profits made, taxes paid and any public subsidies received on a country-by-country (CbC) basis. The say-on-pay measure would let shareholders vote at least every three years on remuneration policies for directors of European Union (EU) listed companies. Background. In June 2007, the shareholders' rights directive became part of EU law...

Published in International
Thursday, 02 July 2015

Final IRS corporate inversion rules retain strict bright-line test

Written by Thomson Reuters

The IRS issued final regulations on whether an expanded affiliated group (EAG) has substantial business activities in a foreign country for purposes of determining if it should be treated as a surrogate foreign corporation (i.e., an inverted foreign corporation). The final rules retain the 25% employee, asset, and income bright-line test contained in the temporary 2012 regulations...

Published in International
Thursday, 02 July 2015

EC proposes plan for corporate reform

Written by Thomson Reuters

The European Commission presented a comprehensive action plan to fundamentally reform corporate taxation in the European Union (EU). The Commission's plan, called the Action Plan for Fair and Efficient Corporate Taxation, represents a second and more comprehensive step toward reforming corporate taxation in the EU. It is part of the EC's agenda to: • Tackle corporate tax avoidance • Ensure a fairer Single Market (the common area between the 28 EU nations where goods, services, capital, and persons can circulate freely) • Promote jobs, growth and investment in Europe The action plan includes a strategy to relaunch the Common Consolidated Corporate Tax Base (CCCTB) using a step-by-step approach. Single set of rules The CCCTB offers a single set of rules companies could use to calculate their taxable profits in the EU instead of having to deal with different national systems and filing a tax return in every country where they operate...

Published in International
Thursday, 02 July 2015

OECD outlines plan for BEPS reporting by country

Written by Thomson Reuters

The Organisation for Economic Cooperation and Development (OECD) published its proposals for country-by-country (CbC) reporting under Action 13 of its base erosion and profit shifting (BEPS) project. The BEPS project seeks to ensure that profits are taxed where economic activity generating the profits is performed and where value is created. Among other things, the CbC package contains: Model legislation that countries may use to require the parent entity of a multinational enterprise (MNE) group to file the CbC report in its jurisdiction of residence, including backup filing requirements when that jurisdiction doesn't require filing. The model legislation doesn't take into account the constitutional law and legal system or the structure and wording of the tax legislation of any particular jurisdiction...

Published in International
Tuesday, 02 June 2015

EC unveils digital single market strategy

Written by Thomson Reuters

The European Commission (EC) disclosed details of a 16-step strategy to create a digital single market that it believes will improve commerce for consumers and businesses. The plan is to break down regulatory walls to facilitate a transition to one market from 28 separate markets. The move is expected to affect not only online providers of goods and services, but also the film, television, and telecommunications industries. The strategy includes reducing the administrative burdens of complying with different value added tax (VAT) regimes on cross-border sales...

Published in International
Tuesday, 02 June 2015

Courts reject Nortel bankruptcy allocation

Written by Thomson Reuters

A U.S. bankruptcy court in Delaware ruled that $7.3 billion in proceeds from the bankruptcy sales of Nortel Networks Inc...

Published in International
Tuesday, 02 June 2015

EC probe could have “material” implications for Apple

Written by Thomson Reuters

The European Commission's (EC's) investigation of Apple's transfer pricing arrangements in Ireland could have a "material" effect on the company. If it is determined that Ireland's corporate tax practices amount to illegal state aid, the EC could require Dublin to recover as much as ten years of past taxes from the technology giant. Apple told the Securities and Exchange Commission that it has been unable to estimate the amount of the potential past taxes but that it could be "material." Earlier this year, the company said that a tax recovery could adversely affect its cash flow and financial condition...

Published in International
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