Asia-Pacific

Armenia

Switzerland and Armenia signed tax treaty protocol November 12, reducing dividend tax rate and implementing standards on treaty abuse, mutual agreement procedure, and exchange of information: Switzerland SIF→

November 18, 2021

Asia-Pacific

Taiwan–Saudi Arabia tax treaty enters into force

November 18, 2021

The tax treaty signed by the governments of Taiwan and Saudi Arabia in December 2020 entered into force on November 1, following the necessary exchange of diplomatic notes, according to a November 18 announcement from . . .

Africa

International tax-related information exchange generates billions in revenue, Global Forum reports

November 17, 2021

The automatic exchange of financial account information between countries is linked directly to at least EUR 3 billion in additional tax revenues; it also has contributed, through voluntary disclosure and other programs, to more than EUR 112 billion in additional tax revenues, according to a November 17 . . .

Accounting

Singapore withholding tax guidance clarifies payment date determination

November 15, 2021

The Inland Revenue Authority of Singapore, in a new e-Tax guide dated November 8, explains the determination of the date of income payments for purposes of withholding tax requirements for payments made or deemed made to non-resident persons . . .

Africa

Singapore and Cabo Verde sign tax treaty

November 12, 2021

The Inland Revenue Authority of Singapore announced on November 12 that the governments of Singapore and Cabo Verde on August 12 signed a treaty to eliminate double taxation and . . .

Asia-Pacific

Australia updates guideline on simplified transfer pricing record-keeping options

November 12, 2021

The Australian Taxation Office on November 11 amended its practical compliance guideline on simplified transfer pricing record-keeping options to provide maximum and minimum . . .

Asia-Pacific

Australian Taxation Office’s transfer pricing audit of ResMed: an illustrative model

November 12, 2021

New York City Economist Dr. J. Harold McClure discusses medical equipment company ResMed’s settlement with the Australian Tax Office (ATO) for USD 381.7 million in additional taxes in connection with an ATO audit over certain transfer pricing issues between . . .

Asia-Pacific

Taiwan tax agency clarifies R&D tax credit eligible expenses

November 11, 2021

Taiwan’s National Taxation Bureau on November 11 stated that not all expenditures resulting from research and development (R&D) departments can be declared for tax credits even when . . .

Africa

‘Tax Inspectors Without Borders’ expands developing country tax and transfer pricing assistance

November 9, 2021

Tax Inspectors Without Borders – a joint initiative of the OECD and United Nations Development Programme – expanded the scope of its assistance to developing country tax administrations, according to the initiative’s 2021 annual report released November 9, amid challenges faced by . . .

Asia-Pacific

Taiwan reminds multinational group affiliates of transfer pricing filing obligations

November 9, 2021

In a November 9 release, the National Tax Bureau of the Republic of China (Taiwan) states that Taiwan-based constituent entities of multinational groups meeting the relevant threshold must submit the master file or country-by-country report within . . .

Asia-Pacific

Japan–Serbia tax treaty to enter into force

November 8, 2021

The governments of Japan and Serbia on November 5 completed the necessary exchange of diplomatic notes for the entry into force of the tax treaty between the two countries that was signed in July 2020 and will generally have effect beginning in . . .

Asia-Pacific

Jordan publishes executive instructions for transfer pricing rules

November 8, 2021

Nour Ali, DNV, discusses Jordan’s September 16 release of the country’s latest transfer pricing guidance regarding the disclosure form, local file, master file, and country-by-country report, along with specific . . .

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

November 4, 2021

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Asia-Pacific

Cairn and India to resolve long-running tax dispute

November 3, 2021

On November 3, UK-based Cairn Energy announced that it is engaging with the Indian government, under the provisions of the recent Indian legislation withdrawing a controversial retroactive tax law, to resolve its more than USD 1 billion tax dispute with the country and obtain . . .

Asia-Pacific

Singapore finance minister explains why global tax deal is a ‘challenging development’

November 2, 2021

In a November 1 reply to a parliamentary question about potential revenue gains under the OECD global tax deal, Singapore’s Minister for Finance Lawrence Wong explained that such estimates are not so simple and, moreover, the agreement presents some challenges for . . .

Americas

UK consults on introduction of corporate re-domiciliation regime

November 2, 2021

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Asia-Pacific

Spanish Supreme Court denies access to MAP in domestic GAAR tax case

November 2, 2021

Aitor Navarro, Carlos III University, discusses the September 22 Spanish Supreme Court decision regarding SGL Carbon Holding (ECLI:ES:TS:2021:3572), addressing the denial of a mutual agreement procedure (MAP) initiation request on the grounds of tax abuse in a case involving . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Asia-Pacific

Bahrain tax guide reviews mutual agreement procedure

October 26, 2021

Bahrain’s National Bureau of Revenue in September issued guidance on the mutual agreement procedure (MAP) for resolving international tax and transfer pricing disputes; it is intended to. . .

Asia-Pacific

Singapore updates tax treaty guide to address arbitration

October 25, 2021

The Inland Revenue Authority of Singapore on October 23 issued a revised edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax treaties.

Africa

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

October 25, 2021

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities’ introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and Africa . . .

Asia-Pacific

Pakistan reportedly will be out an extra USD 150 million in tax revenues annually if it stays outside global tax deal, according to OECD estimates: Mehtab Haider / The News→

October 21, 2021

Asia-Pacific

Thailand adopts new tax incentives for industry and automation investments

October 21, 2021

The Thailand Board of Investment on October 11 approved new tax incentives to encourage companies to invest in productivity enhancement and automation to speed up its “Industry 4.0” initiative, including . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Africa

Country-by-country reporting adopted in more than 100 jurisdictions, OECD reports

October 18, 2021

More than 100 jurisdictions have in place a domestic legal framework for requiring country-by-country reporting by large multinational enterprises, according to an OECD report released October 18, noting that additional jurisdictions have . . .

Asia-Pacific

Thailand clarifies its transfer pricing documentation requirements

October 15, 2021

Paul Ashburn and Rohit Sharma, HLB Thailand, discuss Thailand’s September 30 release of a notice on the transfer pricing documentation that corporate taxpayers will be required to provide to support their analysis of the terms of their . . .

Asia-Pacific

India extends applicability of transfer pricing safe harbour rules for another year

October 12, 2021

Gaurav Jain and Priya Bhutani, New Delhi, discuss India’s September 24 extension of the existing transfer pricing safe harbour rules to financial year 2020-21 – welcome news to eligible corporations, but certain stakeholders, such as small and medium enterprises . . .

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Asia-Pacific

Hong Kong plans tax changes to get off EU’s ‘gray list’

October 6, 2021

The government of Hong Kong on October 5 responded to the EU’s inclusion of Hong Kong in its updated “gray list” of jurisdictions that do not yet comply with certain international tax standards, stating that it . . .

Africa

EU removes three jurisdictions from tax ‘black list’

October 5, 2021

The European Council on October 5 approved the removal of Anguilla, Dominica, and Seychelles from the EU’s list of non-cooperative jurisdictions for tax purposes, the so-called “black list,” and moving . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Asia-Pacific

Ukraine advances tax treaty protocols with Denmark and Qatar

September 30, 2021

Iryna Kalnytska, GOLAW, discusses the Ukraine government’s September 2 publication of a draft tax law ratifying the protocol to the 1996 tax treaty between Ukraine and Denmark, along with the same day signing of a protocol with . . .

Asia-Pacific

Australian Taxation Office reacts to loss in Glencore transfer pricing case

September 28, 2021

The Australian Taxation Office, in a September 28 decision impact statement, sets out its views on the outcome of the Glencore transfer pricing dispute, in which the Federal Court of Australia held that the ATO had misapplied . . .

Asia-Pacific

Indian decision on COVID-induced forced stay has tax implications for MNEs

September 28, 2021

Ashish Mehta and Ujjval Gangwal, Khaitan & Co., discuss the Indian Supreme Court’s September 7 decision not to entertain taxpayer petitions seeking an exclusion of COVID-19-induced forced/involuntary stay for financial year 2020-21, for the purpose of . . .

Americas

OECD’s GloBE rules: Blending in with jurisdictional blending

September 24, 2021

Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of “jurisdictional blending” for computation of effective tax rate, and consequent top-up tax, is one of the most pivotal . . .

Asia-Pacific

Philippines introduces digital services tax

September 22, 2021

The Philippines House of Representatives on September 21 approved a 12% value-added tax (VAT) on digital transactions that will apply to foreign corporations selling digital services in . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Asia-Pacific

Australia plans to add 10 new tax treaties in next two years

September 17, 2021

Australia plans to expand its existing network of 45 bilateral tax treaties by entering into 10 new and updated tax treaties by 2023, according to a September 15 announcement from . . .

Africa

India proposes rules to implement farewell to the retro tax

September 16, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses India’s Central Board of Direct Taxes August 28 publication of a consultation document on proposed rules to remove the controversial retroactive application of a law taxing indirect transfers of assets situated in . . .

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

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