Tax & Accounting Blog

Foreign Trade in the 21st Century

Foreign Trade in the 21st Century

There have been numerous activities related to political changes, technological progress and globalization that have undergone extreme radical transformations since the second half of the 20th century. Foreign Trade has not escaped these transformations causing an accelerated growth that is changing the way countries and companies trade with extraordinary speed. Today, there is not a … Read More

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

On April 27, 2017, Irish Revenue issued its 2016 Annual Report, which discusses Ireland’s participation in the OECD BEPS project during that year. Ireland has joined the OECD Inclusive Framework for the global implementation of the BEPS project. As a member, Ireland has committed to implementing the four BEPS project minimum standards (Read More

Is Everything Negotiable in Trade?

Is Everything Negotiable in Trade?

In January 2017, I wrote an article shortly after the Trump Administration took office discussing their official withdrawal from the Trans-Pacific Partnership (TPP). This answered my own rhetorical question of whether the U.S. withdrawal effectively killed all new multilateral agreements with the response, “it depends on who you ask.”[1]  Since then, many (including … Read More

Netherlands Addresses Parliament Concerns over Tax Rulings

Netherlands Addresses Parliament Concerns over Tax Rulings

On April 14, 2017, the Dutch Finance Secretary wrote a letter to Parliament, the Annex of which addresses Parliament’s questions and concerns over the Netherlands advance pricing agreement (APA) / advance tax ruling (ATR) practice (the “Rulings”). On December 29, 2016, the Netherlands published the Law of December 21, … Read More

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

On March 31, 2017, India enacted Finance Act 2017, which introduces measures in Clause 43 to limit interest expense deductions on related-party debts to 30% of the debtors (Indian company or an Indian permanent establishment (PE) of a foreign company) earnings before interest, taxes, depreciation, and amortization (EBITDA), or 30% of interest paid … Read More