Africa

Germany

Indonesian, Mexican, South African finance ministers join German, US counterparts in op-ed endorsing global minimum tax of at least 15%: Arturo Herrera Gutiérrez, Sri Mulyani Indrawati, Tito Mboweni, Olaf Scholz and Janet L. Yellen / Washington Post→

June 10, 2021

Africa

Israel, United Arab Emirates sign tax treaty: Reuters→

June 2, 2021

Africa

Kenya tax bill alters permanent establishment definition, increases transfer pricing reporting requirements

June 2, 2021

Ian Mota, Rödl & Partner, discusses Kenya’s Finance Bill 2021, which includes a new “permanent establishment” definition, country-by-country reporting requirement, and new rules for determining “control” among related entities . . .

Africa

Hungary, Ireland, UK reiterate resistance to global minimum tax while Germany remains optimistic

May 26, 2021

Hungary, Ireland, and UK officials have again warned that their countries will not accept the global minimum . . .

Africa

South Africa guidance addresses taxation of foreign dividends other than dividends paid by a headquarters company: South Africa Revenue Service→

May 25, 2021

Africa

South African tax guidance explains withholding rules on interest, royalties

May 19, 2021

The South African Revenue Service has issued guidance clarifying the application of withholding tax provisions applicable to interest and royalties in two interpretation notes . . .

Africa

African Tax Administration Forum proposes simpler, more equitable “Pillar One”

May 18, 2021

The African Tax Administration Forum on May 12 sent a revised Pillar One proposal to the OECD Inclusive Framework, emphasizing . . .

Africa

If US and EU states can convince large emerging economies to adopt GloBE, MNEs will pay double-digit billions more tax, face increased complexity, Professor says: Joachim Englisch / SSRN→

May 13, 2021

Africa

Kenyan court suspends implementation of minimum tax on revenues

May 11, 2021

The Kenyan High Court sitting in Machakos issued an order suspending the implementation of Kenya’s new minimum tax on business gross revenues on April 19 . . .

Africa

OECD’s Global Forum to train African tax officials

May 4, 2021

The OECD’s Global Forum launched in April its “Train the Trainer” pilot program – a move to provide local training to African tax auditors and investigators . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Africa

Switzerland, Luxembourg do not appear on tax blacklists while island nations do, creating the perception of racial bias, professors say: Steven A. Dean & Attiya Waris / SSRN→

April 19, 2021

Africa

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

April 12, 2021

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Africa

US offers new “Pillar One” compromise plan for taxing large multinationals

April 8, 2021

The Biden administration has proposed a new “Pillar One” scheme for taxing multinational groups to a coalition of 139 countries . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Africa

UN tax committee releases updated model treaty language on automated digital services

April 7, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters today released its final draft of proposed Article 12B and commentary on income from automated digital . . .

South Africa High Court rules on its power to review tax authority actions

March 30, 2021

Prenisha Govender of Baker McKenzie, Johannesburg, discusses a March 11 High Court of South Africa judgment that addresses access to the courts in tax disputes . . .

Africa

OECD details 30 countries’ approach to cross-border tax dispute arbitration

March 25, 2021

The OECD today added information to its website on 30 countries’ processes for arbitrating cross-border tax . . .

Africa

EU to implement digital levy regardless of OECD-led effort

March 16, 2021

The EU Commission will continue to press ahead with its proposal for an EU digital levy to fund EU operations even if a global international tax . . .

Africa

South Africa issues private ruling on taxation of transfer of reinsurance business from a resident company to a local branch of a foreign company: South African Revenue Service→

March 16, 2021

Africa

Zambia introduces country-by-country reporting

March 3, 2021

Rubeena Dina and Kennedy Munyandi, of GTS Africa, discuss the Zambian government’s issuance of transfer pricing regulations addressing country-by-country reporting, which became effective January 1 . . .

Morocco notes its removal from EU’s grey list of noncooperative countries: Morocco Ministry of Finance→

February 26, 2021

Africa

US drops demand that “pillar one” global tax compromise be a safe harbor

February 26, 2021

The US will no longer require that any coordinated “Pillar One” update to the international tax and transfer pricing rules be drafted as a “safe harbor.” The announcement . . .

Africa

Latest updates to EU list of non-cooperative jurisdictions

February 24, 2021

Francesca Amaddeo, a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the February 22 update to the EU’s list of non-cooperative jurisdictions for tax purposes . . .

Africa

Countries agree to new rules for private tax ruling transparency

February 22, 2021

An OECD-led coalition of 139 countries working together on cross-border tax issues known as the “Inclusive Framework on BEPS” has agreed to a new method for assessing whether countries meet global minimum standards for private tax ruling . . .

Africa

Seychelles government describes tax reform efforts aimed at ensuring its removal from the EU tax blacklist: Ministry of Finance, Economic Planning and Trade, Republic of Seychelles→

February 22, 2021

Africa

Proposed UN model treaty article on automated digital services is simpler than OECD/G20 Inclusive Framework proposal and preserves taxing rights of developing countries, IMF subcommittee says: International Monetary Fund→

February 19, 2021

Africa

Feedback sought on UN model tax treaty provision clarifying taxation of software payments

February 17, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has released a discussion draft and . . .

Africa

Analysis of MNE data in 34 countries shows that thin capitalization rules, by raising the cost of capital, can significantly affect real investment: International Monetary Fund→

February 17, 2021

Africa

UN model treaty draft article 12B allows developing countries to use more straightforward domestic rules to tax the digital economy, WBG staff writes: World Bank Group→

February 17, 2021

Africa

South Africa prevails with a TNMM analysis in transfer pricing dispute, but should it have?

February 17, 2021

New York City economist, Dr. J. Harold McClure, discusses South Africa’s win in a transfer pricing dispute with a catalytic converter manufacturer in ABC (Pty) Ltd. v. Commissioner . . .

Africa

OECD publishes assessment of cross-border tax dispute resolution in 13 more countries

February 17, 2021

The OECD on February 1 published assessments of the cross-border tax dispute resolution processes in Aruba, Bahrain . . .

Africa

Stakeholders weigh-in on BEPS Action 14 standards for cross-border tax dispute resolution

February 10, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, discusses an OECD consultation meeting, held February 1, addressing OECD Secretariat proposals with respect to a 2020 review of BEPS Action 14, concerning cross-border tax dispute resolution . . .

Africa

First Look: OECD consultation focuses on improving cross-border tax dispute resolution

February 1, 2021

The OECD today hosted a consultation meeting on a planned review of minimum standards, agreed to by OECD and G20 countries in 2015, that aim to improve cross-border tax dispute resolution for multinational . . .

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

January 25, 2021

Africa

Rwanda introduces transfer pricing regulations

January 20, 2021

Rubeena Dina, Director at GTS Africa – Mauritius, discusses a Rwandan government ministerial order establishing general rules on transfer pricing . . .

Africa

Transfer pricing and the cumulative advertising effects on sales

January 20, 2021

Dr. Ednaldo Silva, founder and managing director of RoyaltyStat, Bethesda, Md., discusses the effect of advertising on enterprise-level sales, arguing that marketing intangible producing activities such as advertising expenses cannot coexist with the legal concept of limited function distributor or retailer . . .

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

January 19, 2021

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Africa

South Africa invites public comment on advance tax ruling process: South Africa Revenue Service→

January 19, 2021

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

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

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