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INTERNATIONAL TAXES


The EU Joint Transfer Pricing Forum (JTPF) has agreed on its programme of work for the period 2015–2019. The programme of work will consist of monitoring and improving the existing JTPF guidance and developing new tools and guidance where appropriate.

The IRS has confirmed that the US has signed competent authority arrangements (CAA) with Australia and the UK, these are the first arrangements of this kind to be signed and it is anticipated that CAAs with other intergovernmental agreement (IGA) jurisdictions will be signed in the near future.

The European Commission has published a report on analysing tax policy challenges and recent reforms in member states. The report is intended to contribute to discussions on tax policy in the EU. See www.bit.ly/1FD0owj.

The governments of the UK and Japan have published a memorandum of understanding setting out the arbitration process under art 25 of the 2006 double taxation convention, as amended by the 2014 protocol with effect from 12 December 2014.

China has published a discussion draft Implementation measures for special tax adjustments which would comprehensively revise circular 2, China’s main transfer pricing guidance.

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including: Groupe Steria; management fees under UK treaty and minimum alternative tax in India; country by country reporting in Australia; debt capitalisation changes in New Zealand; and measures to encourage multinationals to locate headquarters in Thailand.
 

Commission president Jean Claude Juncker told MEPs last week at a joint meeting of the committees for tax rulings and for economic and monetary affairs that the current system of corporate tax rules is ‘unfit for purpose and unjust.

A new OECD report highlights the benefits of greater co-operation between government financial intelligence units and tax administrations in tackling financial crimes and ensuring tax compliance.

The US Internal Revenue Service is to extend the FATCA transitional rules for withholding on gross proceeds and foreign pass through payments, limited branch and limited FFI status, and registering sponsored entities.

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