Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

January 13, 2021

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

January 13, 2021

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Africa

From January 1, Kenya increases corporate rate to 30%, sets min tax at 1% gross turnover: Kenya Revenue Authority→

January 12, 2021

Africa

Kenya expects 100 nonresident businesses to register by this week to pay 1.5 percent tax on goods and services sold online, anticipates 900 others will join: John Mutha / Business Daily→

January 11, 2021

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Practical obstacles prevent low-income countries from participating in global tax standard-setting through Inclusive Framework, authors say: Rasmus Corlin Christensen, Martin Hearson, & Tovony Randriamanalina / The International Centre for Tax and Development→

December 21, 2020

Africa

Benin introduces transfer pricing private ruling procedure

December 21, 2020

Moïse Gnakouri, a Doctoral researcher at the Catholic University of Louvain, Brussels, Belgium, discusses a new law adopted by the Benin parliament on December 8 that allows multinationals to apply for transfer pricing rulings . . .

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020

Africa

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

December 15, 2020

Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

December 14, 2020

Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→

December 11, 2020

Africa

Transactional profit indicators for the TNMM are not viable

December 9, 2020

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

December 9, 2020

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

88% of countries engaging in automatic exchange of financial account information have satisfactory legal frameworks, Global Forum peer review concludes: OECD→

December 9, 2020

Africa

OECD toolkit helps developing country tax administrations satisfy confidentiality and data security requirements for automatic exchange of information with other countries: OECD→

December 2, 2020

Africa

Shell releases 2019 country-by-country report disclosing revenue, profits, tax paid in 98 countries: Shell.com→

November 30, 2020

Africa

NGO report estimates annual corporate tax avoided per country, says USD 245 billion lost annually from MNEs shifting profits to tax havens: Tax Justice Network→

November 25, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Africa

South Africa considers advance pricing agreement program

November 17, 2020

The South African Revenue Service on November 11 published a discussion paper seeking public feedback . . .

Africa

Zambia’s transfer pricing advances and the Mopani copper mine dispute

November 16, 2020

Dr. J. Harold McClure, New York City, discusses a November 12 OECD case study on Zambia’s landmark Supreme Court victory in a transfer pricing dispute involving the Mopani copper mines and notes transfer pricing issues addressed and not addressed in the Court’s decision . . .

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 2020

Africa

East African nations pledge to jointly address taxation of digital firms

November 13, 2020

Tax officials from Kenya, Uganda, Tanzania, Rwanda, South Sudan . . .

Africa

South Africa extends deadlines to file country-by-country reports: South African Revenue Service→

November 13, 2020

Africa

Burkina Faso deposits BEPS MLI ratification documents with OECD

November 3, 2020

The OECD has announced that Burkina Faso on October 30 deposited instruments . . .

Africa

Zambia proposes changes to transfer pricing documentation requirements

October 27, 2020

Joseph Jalasi and Mailesi Undi of Eric Silwamba, Jalasi, and Linyama Legal Practitioners, Lusaka, discuss the international tax proposals in Zambia’s 2021 budget, released on September 25 . . .

Africa

South Africa presidential commission recommends adoption of digital tax, tax on processed metals, R&D tax credit incentive: Businesstech→

October 27, 2020

Africa

Transfer pricing in Kenya: beyond Unilever

October 22, 2020

New York economist Dr. J. Harold McClure discusses the new Kenya chapter in the United Nations Practical Manual on Transfer Pricing for Developing Countries and Kenya’s loss in a transfer pricing dispute with Unilever . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Africa

The UN transfer pricing manual’s updated China chapter: wine and smartphones

October 20, 2020

Dr. J. Harold McClure, a New York City economist, discusses the newly revised China chapter of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released in advance of the 21st session of Committee of Experts on International Cooperation in Tax Matters . . .

Africa

UN tax committee to consider adding new automated digital services article to model convention

October 20, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss the UN Committee of Experts on International Cooperation in Tax Matters plans to consider at its 21st session a proposed new model tax convention article that addresses automated digital services income . . .

Africa

UN tax committee to weigh updates to model treaty, transfer pricing manual

October 20, 2020

The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its 21st session today, meeting virtually to discuss transfer pricing . . .

Africa

OECD Pillar One: a closer look at the proposal’s impact and the questions that remain

October 14, 2020

Philippe Paumier of VECTOR TP, Paris, takes a closer look at the supporting impact analysis of the OECD blueprint on pillar one and considers the future of the proposal . . .

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