United States: Supreme Judicial Court Hears Argument In First Marblehead Case

An active bench at the Supreme Judicial Court heard oral argument in First Marblehead Corp. & Gate Holdings, Inc. v. Commissioner, Docket No. 2013-P-0935 this morning; posing pointed questions to both parties.

At issue is whether Gate Holdings (“Gate”) is entitled to look to the activities of third-party loan services for purposes of sourcing its loans under Massachusetts SINAA sourcing rules for the financial institution excise tax.   With respect to loans, SINAA activities refer to […]

By |October 8th, 2014|

Nigeria: Sole Risk And Marginal Field Operators Are Now Required To File CIT Returns And Compute PPT According To Equity Interest

The Federal Inland Revenue Service (FIRS) held a stakeholder meeting on 19 September 2014 to sensitise Sole Risk and Marginal Field operators on tax compliance and transfer pricing issues. Returns under the Companies Income Tax Act are now required in addition to Petroleum Profit Tax returns which are to be based on equity interest rather than economic interest.

Read our tax alert uploaded below for further insights.

Download PwC Tax Alert – Sole Risk and Marginal Field Tax […]

By |October 7th, 2014|

Nigeria: OECD Publishes Reports To Address Base Erosion And Profit Shifting Including Revisions To Its Transfer Pricing Guidelines

On September 16, the OECD published the first set of recommendations in connection with its Base Erosion and Profit Shifting (BEPS) action plan. The published papers address some elements of the action plan including: Neutralising the effect of Hybrid mismatch arrangements; Preventing the Granting of Treaty Benefits in inappropriate circumstances; Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance; Feasibility of Multilateral instruments and Addressing the Tax challenges of the digital economy.

Two […]

By |October 7th, 2014|