Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

Africa

COVID-19 test producer Qiagen’s intercompany financing – the transfer pricing issues

October 6, 2020

Dr. Harold McClure, a New York City Economist, discusses an analysis by Vincent Kiezebrink and Jasper van Teeffelen which accuses biotech firm Qiagen of base erosion through the use of intercompany loans . . .

Africa

Australia to change to corporate tax residency test

October 6, 2020

The Australian government will propose to change the corporate residency test used to determine if a company incorporated offshore is liable for income tax in Australia, budget documents released today . . .

Africa

African tax administrators release model digital services tax legislation, say global tax deal unlikely this year

October 1, 2020

The African Tax Administration Forum (ATAF), comprised of tax administrations from 38 African countries, on September 30, published sample digital . . .

Africa

Botswana, Eswatini, Jordan, and Namibia sign Multilateral Convention on Mutual Administrative Assistance in Tax Matters: OECD→

September 30, 2020

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

September 25, 2020

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

September 23, 2020

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available

September 23, 2020

The international tax community needs to again thank McGill Professor Allison Christians for getting ahold of leaked copies of the latest versions of the pillar one and pillar two digital tax . . .

Africa

EU may address public country-by-country reporting this year, German minister says

September 21, 2020

The EU may soon take up the issue of whether country-by-country reports detailing the tax affairs of large multinationals should be made public, German Federal Minister of Finance Olaf Scholz said today . . .

Africa

Customs valuation and intercompany royalties: the Curtis Balkan case

September 21, 2020

Economist Dr. Harold McClure, New York City, discusses transfer pricing issues associated with intercompany royalties . . .

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Africa

Leaked OECD draft pillar one and pillar two digital tax blueprints available

September 3, 2020

McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints . . .

Africa

Taxing somewhere, no matter where: what is the GLoBE proposal really about

September 2, 2020

Dr. Leopoldo Parada a lecturer at the University of Leeds School of Law, UK, makes the case for rejecting the global anti-base erosion proposal, also known as “GloBE,” introduced into the international tax debate by the OECD . . .

Ghana finance minister defends government’s decision to establish entity in Jersey tax haven ensure nontaxation of mining royalties: Modern Ghana→

August 28, 2020

Africa

Ukraine, Kenya agree to negotiate tax treaty: Ukrinform→

August 27, 2020

Africa

Facebook to charge Zimbabwe advertisers VAT

August 25, 2020

Nyasha Nigel Machiri of Baker Tilly Chartered Accountants, Zimbabwe, discusses Facebook’s announcement that they will be charging Zimbabwe advertisers value-added tax on the sale of ads . . .

Africa

The revised operating lease accounting standards: what are the implications for transfer pricing?

August 24, 2020

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Africa

Egypt parliament approves MLI: Egypt Today→

August 21, 2020

Africa

Mauritius introduces new tax holidays, VAT on digital services from foreign suppliers

August 11, 2020

Joe Chan, Managing Partner, ATax Advisors Limited and Zaynab Hisaund, Senior Tax Manager, ATax Advisors Limited, discuss Mauritius’ Finance Bill, enacted August 7 . . .

Africa

Global Forum publishes toolkit to help countries join global treaty providing for cooperation in tax matters: Global Forum on Transparency and Exchange of Information for Tax Purposes→

July 31, 2020

Africa

OECD reports assess cross-border tax dispute resolution in Andorra, Bahamas, Bermuda, BVI, Cayman Islands, Faroe Islands, Macau, Morocco, Tunisia

July 30, 2020

The OECD on July 27 published reports approved by a group of 135+ countries known as the “Inclusive Framework on BEPS” that assess . . .

Africa

New IGF, ATAF initiative seeks to improve mining sector taxation: Intergovernmental Forum on Mining, Minerals, and Sustainable Development→

July 30, 2020

Africa

The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office

July 20, 2020

Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .

Africa

G20 finance ministers again pledge to agree on new multinational group tax rules by year-end

July 20, 2020

In a communique released after their July 18 virtual meeting, G20 finance ministers and central bank governors said that despite the disruptions created by the COVID-19 pandemic, they . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .

Africa

New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior

July 8, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark discusses the OECD’s July 9 release of data on 4,000+ MNE groups . . .

Africa

UN committee to draft model tax treaty provisions addressing digital economy, transfer pricing manual updates approved

July 8, 2020

The UN Committee of Experts on International Cooperation in Tax Matters, at its 20th session, agreed to consider adding new provisions addressing the taxation of the digital economy to the UN Model Double Taxation Convention between Developed and Developing Countries, UN officials . . .

Africa

OECD publishes model rules for tax reporting by gig economy platform operators

July 8, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the OECD’s July 3 release of model rules for tax reporting by platform operators. . .

Africa

Nigeria clarifies new tax on nonresident digital businesses

July 6, 2020

Gabriel Nwodo and Oluwapelumi Omoniyi of AELEX, Nigeria, discuss a new Nigerian order addressing when a digital business operated by a nonresident company is deemed to have a significant economic presence in Nigeria and is thus subject to tax . . .

Africa

Draft toolkit on the art of tax treaty negotiation offers tips for developing countries

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .

Africa

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

June 29, 2020

Economist Dr. J. Harold McClure, New York, NY, discusses likely transfer pricing issues associated with Gilead Sciences’ COVID-19 therapy, remdesivir, comparing the transfer pricing treatment of Gilead Sciences’ blockbuster HIV and hepatitis C virus drugs . . .

Africa

Finland funds ATAF effort to strengthen African tax systems: African Tax Administration Forum→

June 24, 2020

Americas

Canada-Madagascar tax treaty enters into force: Government of Canada→

June 24, 2020

Africa

Zambia terminates tax treaty with Mauritius: Chris Phiri / Zambia Reports→

June 24, 2020

Africa

The OECD’s “no Plan B” approach on digital taxation backfires

June 22, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, discusses the breakdown of global digital tax talks and the likely future of negotiations . . .

Africa

Transfer prices based on EBITDA, not EBIT

June 17, 2020

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

Taxing offshore indirect transfers, the Platform’s new toolkit

June 10, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland writes about the Platform for Collaboration on Tax’s June 4 toolkit on taxation of offshore indirect transfers . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin