Tax & Accounting Blog

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

Mexico Publishes Modifications to Transfer Pricing Documentation Requirements

Mexico Publishes Modifications to Transfer Pricing Documentation Requirements

On April 3, 2017, Mexico’s Office of the Taxpayer Advocate (PRODECON) published a final report for presenting the master file, local file and country-by-country (CbC) report under Article 76-A of the Income Tax Law. These documentation requirements apply from January 1, 2016, with initial CbC reports due by December 31, 2017 … Read More