Featured News

Asia-Pacific

Korea expands R&D tax credit, other technology tax incentives

February 11, 2020

Unghwan Rap Choi, Esq., Ph.D., Partner and International Tax Leader at CKP, LLP, Irvine, California, discusses new Korean government tax incentives offered for research and development . . .

Africa

Zimbabwe backdates tax holiday for Huawei Technologies

February 10, 2020

Nyasha Nigel Machiri of Baker Tilly Chartered Accountants, Zimbabwe, discusses a tax holiday granted to Huawei Technologies Co., Ltd., by the government of Zimbabwe . . .

Featured News

Countries launch review of country-by-country reporting framework for multinational groups

February 9, 2020

The Inclusive Framework on BEPS, an OECD-led group of 137 countries working together on

Europe

Switzerland tax officials update intercompany loan interest rates

February 7, 2020

Elisa Kaminsky of BaseFirma, Miami, writes that Switzerland tax authorities recently issued updated safe harbor interest rates for intercompany loans for a variety of scenarios . . .

Asia-Pacific

Australian tax agency reveals plan to scrutinize non-arm’s length arrangements involving intangible assets

February 5, 2020

David Lewis, Managing Director of Duff & Phelps Australia Pty Ltd., Melbourne, discusses Australian Taxation Office (ATO) transfer pricing guidance issued January 22 which provides examples of arrangements involving intangibles that the agency considers to not be arm’s length . . .

Americas

McDonald’s Brazil subsidiary must withhold tax on cost-sharing payments, court rules

February 4, 2020

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, São Paulo, discusses a problematic decision of the Brazilian Administrative Tax Court in a case brought by a McDonald’s subsidiary concerning income tax withholding on payments made under a cost-sharing agreement . . .

Asia-Pacific

India budget amends key tax rules affecting foreign investors

February 1, 2020

Rajesh H. Gandhi and Gaurav Chandak of Deloitte Haskins & Sells LLP, Mumbai area, India, provide a comprehensive assessment of the tax provisions in today’s India budget that are of interest to foreign investors . . .

Africa

137 countries adopt “unified approach” but global tax deal remains uncertain

February 1, 2020

In a statement released after their January 29–30 meeting, 137 countries that make up the “Inclusive Framework on BEPS” renewed their commitment to try to reach an agreement on an update to the tax rules for multinational groups by the end of 2020 using a two-pillar approach. The member countries also adopted the OECD’s proposed “unified approach,” with important modifications and clarifications, as the basis for further negotiations on pillar one . . .

Asia-Pacific

Japan stakes out position in OECD-led international tax negotiations

January 28, 2020

Yoshimura Masao, a professor at Hitotsubashi University, discusses the Japanese government’s negotiating position concerning the OECD’s project to update the international tax rules to address the digitalisation of the economy . . .

Dominican Republic

Dominican Republic updates transfer pricing documentation thresholds, tax haven list

January 27, 2020

The Dominican Republic earlier this month issued notices changing the threshold amount for transfer pricing documentation purposes and updating a listing of countries that will not be considered preferential regimes for tax purposes, writes Elisa Kaminsky, BaseFirma, Miami . . .

Denmark

Denmark court applies broad interpretation of transfer pricing law

January 21, 2020

Peter S. Andersen, a Transfer Pricing Partner at Questro International, Amsterdam, discusses a decision of Denmark’s National Tax Court published January 3 that adopts an expansive view of what constitutes a “controlled transaction” for purposes of Denmark’s transfer pricing legislation . . .

Africa

The train has left the station: OECD tax officials discuss state of play for pillar one and two

January 20, 2020

Oliver Treidler of TP&C GmbH, Berlin discusses a January 16 tax conference sponsored by the German Federation of Industry which featured discussion and updates by OECD leadership and a German tax official concerning the negotiations surrounding pillar one and two and potential updates to tax dispute avoidance and dispute resolution mechanisms. . . .

Americas

IRS announces intent to grant some multinationals relief from double tax on deemed repatriation

January 20, 2020

The US IRS on January 17 announced that it will consider granting multinationals relief from double taxation resulting from . . .

Americas

Maryland lawmakers propose tax on digital advertising revenue

January 15, 2020

Maryland legislators on January 8 introduced a bill proposing a new tax on the revenue of large companies that advertise to individuals located in Maryland through a . . .

Europe

Dutch government adds two countries, removes four in 2020 update to low-tax jurisdiction list

January 15, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Dutch government’s December 18 update to its list of low-tax jurisdictions and the list’s implications for multinational taxpayers . . .

Featured News

IBOR reform: why transfer pricing professionals need to start paying attention

January 15, 2020

Casimir Leuridan and Melanie Beirens of Zanders, Belgium, discuss the implications of the discontinuance IBOR, scheduled for the end of 2021, on transfer pricing professionals . . .

Americas

Panama tax authority updates country-by-country reporting filing deadlines, notification requirements

January 13, 2020

Elisa Kaminsky of BaseFirma, Miami, discusses new Panama country-by-country reporting and notification requirements issued late December . . .

Digital Economy

Italy adopts digital services tax, notional interest deduction

January 8, 2020

MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, Switzerland, discusses Italy’s 2020 budget law, which includes several tax provisions of interest to multinational enterprises investing in Italy . . .

Europe

Luxembourg enacts tax laws implementing 2020 budget proposals

January 8, 2020

Danny Beeton, Of Counsel, Arendt & Medernach, Luxembourg and London, discusses new tax laws adopted by Luxembourg on December 20 that affect multinationals . . .

Europe

Draft German tax law has big implications for transfer pricing

January 6, 2020

Oliver Treidler and Tom-Eric Kunz, of TP&C GmbH, Berlin, discuss a proposed law introduced by Germany’s Ministry of Finance on December 10 that would have a substantial impact on day-to-day transfer pricing in Germany . . .

Africa

New Cote D’Ivoire law clarifies country-by-country reporting, requires greater tax transparency

January 6, 2020

Moïse Gnakouri, Ph.D., a researcher at the Catholic University of Louvain, Brussels, discusses a Côte d’Ivoire law published in the official gazette on December 27, 2019, that clarifies country-by-country reporting for multinational groups and that addresses tax evasion . . .

Americas

Spain poised to enact digital services tax despite US threats of retaliation

January 2, 2020

Alma Delia Virto Aguilar, Ph.D., a visiting researcher at the University of Salamanca, discusses Spain’s plans to enact a digital services tax on the revenue of large multinationals . . .

Europe

2020 Dutch Tax Plan passes: relevance for multinational enterprises

December 30, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, provide an update on the Dutch 2020 tax plan which significantly changes the taxation of multinationals . . .

Featured News

OECD publishes updated country-by-country reporting guidance, notification requirements

December 30, 2019

The OECD on December 23 released additional interpretative guidance on country-by-country . . .

Asia-Pacific

Turkey enacts 7.5 percent digital service tax

December 22, 2019

Ramazan Biçer, at partner at Centrum, Istanbul, discusses the details of Turkey’s 7.5 percent digital services tax on the revenue of large multinationals, enacted into law earlier this month and set to go into effect April 1, 2020 . . .

Americas

Officials discuss aligning Brazil’s transfer pricing laws with OECD standards

December 20, 2019

Francisco Lisboa Moreira, a tax partner, Bocater Advogados, São Paulo, discusses Wednesday’s public joint-meeting between OECD and Brazil’s tax authority which again addressed aligning Brazil’s transfer pricing regime of Brazil with OECD standards . . .

Africa

US Treasury official defends “pillar one” safe harbor proposal for new global tax rules

December 20, 2019

A senior US Treasury official on December 19 said that the US is recommending that the OECD’s proposal for a “unified approach to pillar one” be rewritten as an optional safe harbor rule because even a watered-down version . . .

Asia-Pacific

Israeli court sides with Broadcom, concludes that business restructuring does not trigger tax

December 17, 2019

Jacky Houlie, of JH & Co. Law Office, and Shlomo Hubscher, of JH Consulting Ltd, discuss a landmark decision of Israel’s Lod District Court, released last week, which rejected the tax authorities’ position on the classification of Broadcom Israel’s business restructuring from a tax and transfer pricing perspective . . .

Americas

Brazilian court rules that Oracle subsidiary may deduct outbound royalty payments

December 16, 2019

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, São Paulo, discusses the Oracle case, decided by Brazil’s highest administrative tax court on December 3 . . .

Europe

Germany advances new EU financial transaction tax proposal

December 16, 2019

German tax practitioner, Ninja-Antonia Reggelin, discusses the latest proposal for an EU-wide financial transactions tax, presented by German Finance Minister Olaf Scholz on December 9 . . .

Cyprus

Ukraine-Cyprus tax treaty protocol would alter taxation of indirect real estate transfers

December 13, 2019

Leonid Karpov a partner at AC Crowe, Ukraine, discusses the new Ukraine-Cyprus tax treaty protocol, ratified on October 30 by Ukraine’s Parliament. . .

Americas

The final and proposed BEAT regulations: what changed, what’s new, and what’s next?

December 11, 2019

Amanda Varma, a partner with Steptoe & Johnson, Washington, DC, analyzes the final and proposed base erosion anti-abuse tax (BEAT) regulations, issued on December 2 . . .

Europe

Why the EU Commission won’t appeal the Starbucks judgment

December 10, 2019

Dimitrios Kyriazis, Head of the Law Faculty at the New College of the Humanities, London, discusses the Commission’s decision to not appeal the Starbucks State and the implications of the Court’s judgment for transfer pricing in Europe . . .

Featured News

Royalty rates for licensed intangibles and minerals

December 10, 2019

Ednaldo Silva, Founder & Director at RoyaltyStat, discusses the economic concept of royalties . . .

Digital Economy

OECD holds consultation on “pillar two” global tax for multinationals, pledges continued work on “pillar one”

December 9, 2019

The OECD on December 9 held a public consultation in Paris, providing a forum for stakeholders to express their views on how to best design a “pillar two” global minimum tax on multinational group profit, also known . . .

Asia-Pacific

Georgia adopts changes to transfer pricing legislation

December 6, 2019

Gela Barshovi, Tax Advisor and Managing Partner at TPsolutions, Tbilisi, Georgia, discusses December 2 amendments made to Georgia’s transfer pricing laws . . .

Europe

Netherlands publishes first summaries of private tax rulings issued to MNE groups

December 5, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands” publication, on October 16, of the first redacted summaries of private tax rulings . . .

Africa

More highlights on Zimbabwe’s proposed 5 percent digital tax

December 5, 2019

Nyasha Machiri, a Senior Tax Consultant at Baker Tilly Chartered Accountants, discusses the latest information about Zimbabwe’s proposed digital tax . . .

Africa

Is the US about to blow up the OECD’s compromise “pillar one” plan for taxing multinational group profit?

December 5, 2019

In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECD’s compromise proposal to overhaul the rules for allocating multinational group profit and related taxing. . .

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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