International TaxIn the current challenging environment, executives are looking to align their global tax position with their overall business strategy to maintain competitive advantage and provide value to shareholders. | New OECD report addresses hybrid mismatch arrangements In the latest of a series of reports focusing on aggressive tax planning, the OECD describes the most common types of hybrid mismatch arrangements (i.e., arrangements exploiting differences in the tax treatment of instruments, entities or transfers between two or more countries) and the effects they aim to achieve. Concluding that the same concern that exists in relation to distortions caused by double taxation exists in relation to unintended double non-taxation, the report makes a number of specific recommendations to countries to address the policy issues. Download the report here.Transfer pricing information at your finger tips Quickly identify the transfer pricing rules, practices and approaches adopted by more than 55 countries and territories in our Transfer Pricing Reference Guide for 2011. OECD publishes scoping paper on transfer pricing and intangibles The Organization for Economic Cooperation and Development's (OECD) project will take on issues in transfer pricing for intangible property. We summarize the seven candidates for guidance in our alert. Global Dispatch Global Dispatch keeps you informed about recent international tax issues around the world affecting multinationals. The February 2012 issue addresses: Tax Court of Canada issues landmark decision on "beneficial ownership" -- Argentina unilaterally terminates tax treaty with Switzerland -- Argentine tax authorities implement new "Early Import Declaration" mechanism -- Mexico reorganizes Certified Company Program; tax consequences for IMMEX companies -- Mexican tax refund opportunity for international airlines operating in Mexico --Belgium-Democratic Republic of Congo tax convention in force; Congo's first tax treaty -- Danish exposure draft includes important changes to company taxation -- Irish government publishes Finance Bill 2012 -- Indian tribunal rules on characterization of entities' activities for transfer pricing purposes -- Indonesian regulation affects MAP and APAs among other topics. International Tax Talk webcast series Many international corporations find it a challenge to keep up with frequent changes in the global tax legislative and regulatory environment. To help address this challenge, Ernst & Young LLP cordially invites you to this quarterly series which provides you with information on major tax law changes in the countries and jurisdictions covered by our US-based Foreign Tax Desks. The inbound guide to US corporate tax As the world’s largest economy, the United States provides abundant opportunities in which to operate. It also delivers a tax code that contains more than 20 volumes in some 17,000-plus pages. Although not all provisions necessarily apply to inbound investors, missteps and lack of information can create an undue risk of future controversy. Ernst & Young is here to help (pdf, 1.3mb) . International Tax updates now available via podcast! International Tax update available via podcast! Stay up to date on the latest thinking from Ernst & Young's International Tax Services with our podcast channel. Subscribe to our Global Dispatch podcast for automatic monthly updates. |
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