International Tax News

China Revises Transfer Pricing Rules

In a long-awaited announcement, China updated its special tax adjustment measures. The Special Tax Investigations, Adjustments and Mutual Agreement Procedures (Announcement 6) integrates elements of the Base Erosion and Profit Shifting (BEPS) transfer pricing work of the Organisation for Economic Co-operation and Development. Clarifying positions It should help taxpayers better understand the focus areas and…

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IRS Adds FAQs on FATCA Beneficial Owner Requirements

The IRS recently added three frequently asked questions to its Foreign Account Tax Compliance Act (FATCA) compliance page elaborating on identification requirements for a beneficial owner withholding certificate. Question: Under what circumstances is a withholding agent required to collect a foreign taxpayer identification number (TIN) or date of birth on a beneficial owner withholding certificate?…

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OECD Issues International VAT/GST Guidelines

The Organisation for Economic Co-operation and Development (OECD) released guidelines on applying Value Added Tax (VAT) and Goods and Services Tax (GST) to international trade transactions. Officially called the Recommendation of the Council on the Application of Value Added Tax/Goods and Services Tax to the International Trade in Services and Intangibles, the guidelines are aimed…

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IRS Explains How Foreign and Domestic Losses Affect Foreign Tax Credit

In a further indication of the IRS’s continued focus on international tax issues, the tax agency updated an International Practice Unit (IPU) summarizing the calculation and recapture of foreign and domestic losses and their impact on the foreign tax credit. Avoiding Double Taxation The United States taxes U.S. persons on their worldwide income, including their…

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EU Proposes Changes to Anti-Money Laundering Rules

In a significant development, the European Union (EU) plans stricter rules that would enable EU citizens to access registers of beneficial owners of companies and trusts without having to demonstrate a “legitimate interest” in the information. Currently, access is restricted to authorities and professionals such as journalists and lobbyists. The new rules are amendments to…

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