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Australia Adds To Diverted Profits Tax Guidance

The Australian Tax Office on February 7 released draft Practical Compliance Guideline 2018/D2 on the operation of Australia’s Diverted Profits Tax for consultation. In the 2016-17 Budget, the Government announced that it would introduce a diverted profits tax (DPT), intended to ensure that the tax paid by significant global entities...

China Sets Out How To Determine Beneficial Owner For Treaties

On February 3, 2018, China’s State Administration of Taxation set out new rules on the disallowance of tax treaty benefits where an entity fails to demonstrate it is the beneficial owner of Chinese assets from which passive income is derived. A beneficial ownership requirement is introduced in treaties to prevent...

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime....

Amazon Inc. Paid Zero in Federal Taxes in 2017, Gets $789 Million Windfall from New Tax Law

From a decades-long strategy of exploiting state sales tax loopholes to its ongoing “HQ2” sweepstakes, Amazon’s leaders have rarely turned down a chance to use the tax system as the source of their competitive advantage. The online retail giant has built its business model on tax avoidance, and its latest...

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