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Through the authority of the Minister of Finance, Government of Indonesia has issued regulations to taxing crypto assets transactions. Although the legal position is still ambiguous, the Minister of Finance chose to go one step further by issuing tax regulations on crypto-asset transactions by applying value added tax (VAT) and withholding tax (WHT) starting in April 2022.
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Late 2021, Finland implemented a regulation concerning taxation of reverse hybrid arrangements included in article 9a of ATAD2 directive (Council directive (EU) 2017/952 amending Directive 2016/1164). The new rules have been implemented in Section 8a of the Finnish act on taxation of cross-border hybrid arrangements (Hybrid Act) and have been applied for fiscal year 2022 onwards.
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The tax regimes of the six countries—the Kingdom of Saudi Arabia, the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar and the United Arab Emirates—that make up the Cooperation Council for the Arab States of the Gulf (better known as the GCC) are evolving and changing rapidly.
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Alex M. Parker, Capitol Counsel LLC, discusses why last year’s OECD-G20 global minimum tax agreement has revealed a scope much broader than most anticipated; provisions of the agreement, revealed in technical commentary released by the OECD in the past months, could affect everything from green energy incentives to affordable housing credits in the U.S.
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Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss the European Court of Justice Advocate General’s April 5 opinion in case C-694/20 that the provisions of DAC6 did not infringe on the right to a fair trial when the name of the intermediary claiming the privilege was not disclosed to tax authorities.
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Adrian ȚAGA, Romania’s National Tax Agency, discusses the April 7 European Court of Justice ruling in case C-333/20 Berlin Chemie A. Menarini that addresses whether in the underlying case the German shareholder has a permanent establishment for VAT purposes in the country of its Romanian subsidiary.
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Kyle Pomerleau, American Enterprise Institute, warns that while the Biden Administration’s recently released 2023 budget—which includes additional reforms to the tax treatment of multinational corporations—is intended to further align the U.S. tax code with the OECD’s Pillar Two model rules and enhance the competitiveness of U.S. multinational corporations, they actually could leave U.S. companies at a competitive disadvantage.
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Annemarie Wilmore, Johnson Winter & Slattery, discusses the latest developments in the Australian case of Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation when the Australian Federal Court issued a further decision on March 22, including its consideration of whether consequential adjustments to the transfer pricing benefit should be made to take into account carryforward losses.
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What’s Next
| 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 |
RECENT COMMENTS
- 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
- Arnold on Global minimum tax’s ‘GloBE’ maze – more than meets the eye!: “Finance for a project We offer Genuine LOAN, BG &SBLC for sale and lease with strong financial backing from top…” September 29 ,2022
- Tom V on Croatia to initiate tax treaty negotiations with the United States: “Has any progress been made on this since 2020 & 2021?” August 23 ,2022
- Robin Prior on Mauritius introduces new tax holidays, VAT on digital services from foreign suppliers: “We supply and support Broadcasting software, all over Africa. We intend to open a branch in Mauritius, and we will…” August 22 ,2022
Expert Author Spotlight
Moïse Gnakouri
Ph.D. Researcher in Tax Law at Catholic University of Louvain
Moïse Gnakouri is a Ph.D. Researcher at Catholic University of Louvain. His Research is focused on tax and development, fiscal federalism, and international tax law.
Moïse holds a law degree from University Paris 1 Panthéon Sorbonne and a master in tax law and wealth management.
Latest posts by Moïse Gnakouri (see all)
- Niger finance bill amends article on taxation of income from transferable securities - February 3, 2022
- Belgian court rules on application of tax general anti-abuse provision - January 18, 2022
- Belgium and France sign new tax treaty - December 13, 2021
- Belgian tax authority clarifies new rule on deduction of foreign business losses - November 22, 2021
- Côte d’Ivoire finance bill 2022 will adjust tax on related party transactions - November 8, 2021
Telephone: +32 465 32 93 48 (Belgium) ; +225 70500536 (Côte d’Ivoire)
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What’s Next
| 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 |
Recent Comments
- 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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Expert Articles
- Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches by Hugo Chary
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- Transfer pricing planning for oil refining, paper and pulp, and other continuous process industries by Gaurav Jain
- Georgia transfer pricing: what multinational groups need to know by Gela Barshovi
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