Daily Tax Update - November 20, 2014: Switzerland Joins Agreement for Automatic Exchange of Information

Switzerland Joins Agreement for Automatic Exchange of Information:  Switzerland signed the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.  Switzerland is the 52nd jurisdiction to sign the agreement.  Fifty-one jurisdictions signed it on October 29, 2014 at the annual meeting of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes in Berlin.  Some jurisdictions plan their first information exchanges by September 2017.  Others, including Switzerland, are expected to follow in 2018.

Indian Court Reportedly Rules in Favor of Shell in Transfer Pricing Case:  The High Court of Bombay ruled in favor of an Indian subsidiary of Royal Dutch Shell in a transfer pricing case regarding the transfer or issuance of shares, according to major media outlets and a statement made to CNBC-TV18 by Mukesh Butani of BMR Advisors, who represented Shell in the dispute.

The court ruled against the Indian government, which had argued that shares transferred from the Indian subsidiary to the parent triggered a transfer pricing assessment.  Mr. Butani said that the tax department could not challenge differences in value under the transfer pricing law because the transfer was a capital account transaction.

Senate Confirms Three Tax Court Judges:  Today, the Senate confirmed Tamara Ashford, Paige Marvel, and Cary Pugh to be judges on the US Tax Court.  This will be a second term for Judge Marvel and a first for Judges Ashford and Pugh.

Miscellaneous Guidance Released:
Revenue Ruling 2014-31 provides various prescribed rates for federal income tax purposes, including the applicable federal interest rates, for the month of December 2014.