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Americas

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

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 . . .

Americas

US IRS releases agent instruction manual on the Section 965 transition tax on untaxed earnings of foreign corporations: Internal Revenue Service→

March 24, 2021
Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Americas

US Tax Court finds microcaptive insurer failed to provide insurance for tax purposes

March 22, 2021

The US Tax Court held on March 10 that a microcaptive insurer purportedly established to insure a number of related construction companies did not actually provide insurance for federal tax purposes because the insurer neither distributed risk nor acted as an insurer commonly would. . .

Americas

Canada’s tax treaty MAP inventory increased in 2019, new report shows

March 22, 2021

The Canada Revenue Agency published on March 8 the annual report on its mutual agreement procedure program for the calendar year 2019, revealing that MAP inventory increased that year. ..

Americas

US Senate Finance Committee chairman to unveil bill to overhaul MNE corporate tax: Allan Smith & Kristen Welker / NBC News→

March 19, 2021
Americas

Canadian mining company seeks NAFTA arbitration in Mexico transfer pricing dispute

March 17, 2021

First Majestic Silver, a publicly traded Canadian mining company, has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in conflict with the terms of an advance pricing agreement. . .

Americas

Mathias Cormann appointed OECD Secretary General 

March 17, 2021

The OECD council on March 15 named former Australian finance minister Mathias Cormann as its next leader beginning in June. He will become the first secretary-general from. . .

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 . . .

Americas

Biden administration negotiating global minimum tax, expected to raise corporate taxes: Jeff Stein / The Washington Post→

March 16, 2021
Americas

NYU law professor Lily Batchelder named US Assistant Secretary for Tax Policy: US Treasury→

March 11, 2021
Americas

Over 100 US legislators support new bill to apply the same tax rate on a company’s overseas profits as on those earned in the US: Lloyd Doggett→

March 11, 2021
Americas

State of Maryland issues guidance on digital products and streaming tax: MD Comptroller→

March 11, 2021
Americas

US corrects final regs (TD 9926), providing guidance related to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the US: IRS→

March 11, 2021
Americas

US IRS corrects PFIC regs: IRS / Federal Register→

March 10, 2021
Asia-Pacific

UK’s Cairn Energy considers ways to monetize arbitration award it won against India in six-year USD 1.7 billion tax dispute: Business Today→

March 10, 2021

   

Americas

Can GILTI and the GloBE be harmonized in a Biden administration?

March 3, 2021

Daniel Bunn, Vice President of Global Projects, Tax Foundation, discusses the need for the US’s GILTI rules and the Inclusive Framework’s GloBE proposal to be harmonized . . .

Americas

US Tax Court decision in Coca-Cola is at odds with economic principles

March 3, 2021

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, Md., identifies flaws in the US Tax Court’s decision in the Coca-Cola transfer pricing dispute . . .

Americas

Professor says Coca Cola case signals possible shift in US transfer pricing litigation, may affect Facebook dispute: Reuven S. Avi-Yonah / SSRN→

March 3, 2021
Americas

Jose E. Murillo named US Deputy Assistant Secretary for International Tax Affairs

March 2, 2021

The US Treasury Department announced today that Jose E. Murillo has been appointed the new Deputy Assistant Secretary for . . .

Americas

Tech group sues Maryland over new tax on digital ads: Ashley Gold/Axios→

March 2, 2021
Americas

Professor advocates sharply progressive US corporate rates to curtail power of the largest corporations, which are monopolies and drive their competitors out of business: Reuven S. Avi-Yonah / SSRN→

March 1, 2021
Americas

US Congresswoman Tlaib calls for financial transactions tax so Wall Street wealth reaches communities: Rashida Tlaib→

March 1, 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 . . .

Americas

US think tank evaluates economic impact of Biden corporate rate hike, minimum tax: Garrett Watson & William McBride / Tax Foundation→

February 26, 2021
G20

Biden Deputy Treasury nominee seeks higher corporate tax rates, level playing field for American companies, ending global corporate tax ‘race to the bottom’: Reuters→

February 24, 2021

   

Americas

Laurence H. Tribe will represent Coca-Cola in transfer pricing dispute with the US IRS: The Coca Cola Company→

February 24, 2021
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 . . .

Featured News

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Europe

In a call with EU Commission’s Valdis Dombrovskis, US treasury secretary commits to re-engage in OECD-led global tax discussion: US Department of the Treasury→

February 23, 2021

     

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 . . .

Americas

Canada’s Supreme Court dismisses tax authority’s appeal in Cameco transfer pricing dispute: Cameco / GlobeNewswire→

February 22, 2021
Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

Illinois budget proposes to cap NOLs to 100K per year, tax dividends from foreign sources like those from domestic sources, add back 168k bonus depreciation: State of Illinois→

February 22, 2021
Americas

Proposals advocating an increase in the GILTI tax rate or a shift to a country-by-country approach would harm US company competitiveness: Caroline L. Harris / US Chamber of Commerce→

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
Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

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 . . .

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • 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

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • 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

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.