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On August 31, 2016 the Liechtenstein Government issued a press release announcing that during its meeting of August 30, 2016 it adopted a Report and Proposal regarding the Multilateral Competent Authority Agreement on the exchange of Country-by-Country Reports (MCAA CbC) as well as the law on the international automatic exchange of Country-by-Country Reports of multinational corporations (CbC Act).

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On August 30, 2016 the Dutch Government announced that the Convention between the Kingdom of the Netherlands and the Federal Democratic Republic of Ethiopia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes and income, which was signed on August 10, 2012 (Hereafter: the DTA) will enter into force on September 1, 2016. Furthermore the Dutch Government announced that the Protocol amending the Convention between the Kingdom of the Netherlands and the Federal Democratic Republic of Ethiopia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, which was signed on August 18, 2014 (Hereafter: the Protocol) will enter into force on September 30, 2016 with retroactive force to September 1, 2016.

Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.

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On August 30, 2016 the European Commission issued a press release announcing that it has concluded that Ireland granted undue tax benefits of up to €13 billion to Apple. According to the EU this is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover the illegal aid.

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On July 15, 2016 the Government of the Republic of Malta and the Government of the Socialist Republic of Viet Nam signed an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (Hereafter: the DTA). The text of the DTA has been made available via the website of the Malta Financial Services Authority.

Although the DTA has been signed, it has not entered into force yet. For the DTA to enter into force, the respective ratification procedures have to have been finalized in both countries.

 

Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.

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On August 26, 2016 the Japanese Ministry of finance issued issued a press release announcing that on August 25, 2016 Japan and Panama signed a Tax Information Exchange Agreement (TIEA). Although signed, the TIEA has not yet entered into force. For the TIEA to enter into force, the respective ratification procedures have to have been finalized in both countries.

Below we will discuss a selection of regulations included in the TIEA of which we think they might interest our readers.

  1. Andorra, Saint Kitts & Nevis and Senegal deposit their Instruments of Ratification regarding the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters
  2. Burkina Faso, Malaysia, Saint Kitts and Nevis, Saint Vincent and the Grenadines and Samoa sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters
  3. The OECD publishes public comments it received on the discussion draft on the design and operation of the group ratio rule under BEPS Action 4
  4. The U.S. Department of the Treasury publishes a White Paper on the European Commission’s State Aid Investigations into Transfer Pricing Rulings
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