Africa

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.

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 . . .

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 . . .

Africa

Kenya contends revenue threshold for companies subject to Pillar 1 of OECD agreement is too high, lower threshold is needed for developing countries to benefit: Kenya Revenue Authority→

October 20, 2021

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 . . .

Africa

European Parliament approves proposal to step up fight against harmful tax practices

October 12, 2021

Vasiliki Koukoulioti, Ph.D. researcher at Queen Mary University of London, discusses the European Parliament’s October 7 adoption of a draft resolution calling for an in-depth reform of European policy to combat harmful tax practices by toughening . . .

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 . . .

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 . . .

Africa

Multilateral convention to implement tax treaty related measures to prevent BEPS gains 96th signatory in Namibia, will enter into force for Andorra and Spain in January 2022: OECD→

September 30, 2021

Africa

Kenya’s minimum tax ruled unconstitutional, government to appeal

September 23, 2021

The Kenyan High Court in Machakos on September 20 held that the minimum tax on business revenues introduced in the country earlier this year was unconstitutional because it would subject taxpayers to . . .

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 . . .

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 . . .

Africa

South Africa seeking to amend tax treaties with Germany, Switzerland, and Eswatini to crack down on tax avoidance and boost tax information exchange: Lameez Omarjee / Fin24→

September 3, 2021

Africa

Togo becomes latest country to endorse global tax reforms

August 31, 2021

The West African nation of Togo became the 140th country to join the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) and the 134th Inclusive Framework member to endorse the two-pillar international tax reform statement released earlier this summer, according to an August 31 . . .

Morocco sets tone in landmark transfer pricing audit case

August 27, 2021

Mourad Chatar & Sarah Bahous, Value Square, discuss the Moroccan tax authorities’ pursuit of a record-breaking tax adjustment of 1 billion Moroccan Dirham (USD 110 million) in a transfer pricing audit of a global player in the fast-moving consumer goods industry, rejecting the . . .

Africa

Most favored nation clauses in tax treaties between high- and lower-income countries operate to the disadvantage of the latter, resulting in significant tax base erosion: Deepak Kapoor / ICTD→

August 26, 2021

Accounting

Dozen countries deemed ‘highly inflationary’ for accounting standard purposes

August 23, 2021

The Center for Audit Quality, in a report published August 20, flagged 12 economies as potentially highly inflationary for purposes of US GAAP Accounting Standards Codification (ASC) 830, Foreign currency matters.

Africa

Cape Verde and Singapore signed tax treaty on August 17: Cabo Verde Inforpress→

August 19, 2021

Morocco publishes mutual agreement procedure guide for resolving tax disputes

August 16, 2021

Nour Ali, DNV, discusses Morocco’s Mutual Agreement Procedure (MAP) guide, released July 5 through the General Tax Administration of the Ministry of Economy and Finance, for resolving tax disputes not in accordance with . . .

Africa

Nigeria’s petroleum industry bill includes tax changes to spur investment, increase revenue

August 16, 2021

Ibrahim Moshood, Centurion Law Group, discusses the Nigerian National Assembly’s July 1 passage of the petroleum industry bill, including tax changes expected to increase . . .

Africa

Maldives, Papua New Guinea, and Rwanda join multilateral treaty for international tax cooperation and exchange of information: OECD→

August 11, 2021

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Accounting

South African tax bill would amend rules on interest deductibility, assessed losses

August 2, 2021

On July 28, the South African Revenue Service and National Treasury released various draft tax bills that would enhance the rules relating to the limitation on interest deductions on payments to persons not subject to tax and would restrict the set-off of the

Africa

New Lesotho–Mauritius tax treaty replaces 1997 treaty connected with African countries’ concerns regarding MNE use of shell companies in Mauritius to dodge taxes: International Consortium of Investigative Journalists→

August 2, 2021

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Switzerland and Ethiopia sign tax treaty

July 30, 2021

The governments of Switzerland and Ethiopia signed a double tax treaty on July 29 in . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Europe

Ireland and Kenya signed double tax treaty on July 21: Irish Department of Foreign Affairs→

July 28, 2021

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Africa

Kenya’s Finance Act 2021 amends tax policy approach to global market

July 19, 2021

Samuel Okumu, Tax Consultant at Rödl & Partner Limited, discusses the Kenyan Finance Act 2021, enacted on June 29, which includes numerous amendments to the Income Tax Act, VAT Act and Tax Procedures Act that focus on taxation of cross-border transactions by . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Africa

African Tax Administration Forum welcomes July 1 consensus on international tax reform as including important developments for African countries but cautions against coercing developing countries: ATAF→

July 9, 2021

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

MNE Tax joins CrossBorder Solutions!

June 23, 2021

MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

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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