Americas

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 . . .

Americas

Dominican Republic guidance addresses transfer pricing thresholds, tax haven list

February 10, 2021

Jessica Barbieri an Associate at BaseFirma Venezuela discusses Dominican Republic tax authority guidance issued earlier this month covering various tax issues, including new transfer pricing thresholds and updates to the tax haven list . . .

Americas

Bermuda lists jurisdictions treated as reportable jurisdictions for country-by-country reporting: Bermuda Ministry of Finance, Treaty Unit→

February 8, 2021

Americas

EU Commission’s grounds for appeal in Apple State aid tax case published: European Court of Justice→

February 3, 2021

Americas

Mexico amends tax rules applying to digital service providers, online platforms

February 3, 2021

Arturo Treviño Villarreal, a Tax Partner at Fratelli Consultores, Monterrey, Mexico, discusses new Mexican rules which entered effect on January 1 that address the income tax and VAT treatment of digital services and transactions performed on technological platforms . . .

Americas

Professor highlights importance of third-party asset valuation to protect US tax system from abuse: Leandra Lederman / SSRN→

February 3, 2021

Americas

US IRS large business and international unit adds compliance campaigns on Puerto Rico individual investors act, taxable asset transactions: Internal Revenue Service→

February 2, 2021

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 . . .

Americas

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

January 28, 2021

Americas

US Democrat senators introduce bill applying GILTI on a per-country basis, eliminating companies’ ability to deduct 10 percent of their tangible assets before GILTI applies: Sen. Amy Klobuchar→

January 28, 2021

Americas

US, Argentina agree to exchange country-by-country reports on large multinationals

January 28, 2021

The US and Argentina have signed a competent authority agreement to exchange . . .

Americas

New Paraguay law extends withholding tax to digital services

January 27, 2021

Valeria Saavedra, Senior Associate, at Basefirma Venezuela, Caracas, discusses a new Paraguay law, effective January 1, which imposes income tax withholding on payments made to nonresidents that provide digital services . . .

Americas

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

January 27, 2021

Americas

COVID-19 and tax treaties: the updated OECD guidance

January 27, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader at GTS (Global Tax Services) UAE, discusses the OECD’s updated guidance on COVID-19 and tax issues, issued January 21 . . .

Americas

In a call to German minister Scholz, new US Treasury secretary pledges active US participation in OECD international taxation effort “to forge a timely international accord”: US Department of Treasury→

January 27, 2021

Americas

US seeks feedback on burdens of reporting foreign currency transactions: IRS / Federal Register→

January 27, 2021

Americas

Janet Yellen sworn in as US Treasury secretary

January 26, 2021

Janet Yellen was sworn in Tuesday as the 78th Treasury secretary in US history . . .

Americas

Mark Mazur confirmed as US assistant secretary for tax policy

January 25, 2021

Mark Mazur, director of the Urban-Brookings Tax Policy Center and a former US Treasury Department assistant secretary for tax policy in the Obama administration, is the Biden administration’s new . . .

Africa

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

January 25, 2021

Americas

US IRS solicits comments on whether treaty-based return position disclosures are burdensome: Internal Revenue Service / Federal Register→

January 25, 2021

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

January 25, 2021

Americas

US Treasury nominee Yellen would delay corporate rate increase because COVID recovery takes priority, would work with OECD to stop tax “race to the bottom”: Thomas Franck / CNBC→

January 20, 2021

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 . . .

Americas

US IRS publishes final PFIC regs (TD 9936): US Treasury / Federal Register→

January 19, 2021

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 . . .

Americas

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

Americas

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→

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→

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

Maryland becomes first US state tax to digital advertising revenue: Celine Castronuovo / The Hill→

US Tax Court upholds IRS disallowance of section 38 and 41(a) research credit for activities undertaken by taxpayer’s subsidiary: US Tax Court→

Coca-Cola’s tax liability in transfer pricing dispute over intangible property licenses could be 12 billion, company reports: David Allison / Atlanta Business Chronicle→

Fordham University law professor Rebecca Kysar appointed Counselor to the Assistant Secretary, Office of Tax Policy: US Treasury Department→

Maryland bill would prohibit tech companies subject to new digital advertising tax from charging the purchaser a separate fee to cover the tax: Danielle E. Gaines / Maryland Matters→

Georgetown professor Itai Grinberg to be new US Deputy Assistant Secretary for Multilateral Tax Office of Tax Policy: US Department of Treasury→

Kimberly Clausing appointed US Deputy Assistant Secretary for Tax Analysis, Office of Tax Policy: US Department of the Treasury→

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

Dominican Republic guidance addresses transfer pricing thresholds, tax haven list

Bermuda lists jurisdictions treated as reportable jurisdictions for country-by-country reporting: Bermuda Ministry of Finance, Treaty Unit→

EU Commission’s grounds for appeal in Apple State aid tax case published: European Court of Justice→

Mexico amends tax rules applying to digital service providers, online platforms

Professor highlights importance of third-party asset valuation to protect US tax system from abuse: Leandra Lederman / SSRN→

US IRS large business and international unit adds compliance campaigns on Puerto Rico individual investors act, taxable asset transactions: Internal Revenue Service→

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

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

US Democrat senators introduce bill applying GILTI on a per-country basis, eliminating companies’ ability to deduct 10 percent of their tangible assets before GILTI applies: Sen. Amy Klobuchar→

US, Argentina agree to exchange country-by-country reports on large multinationals

New Paraguay law extends withholding tax to digital services

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

COVID-19 and tax treaties: the updated OECD guidance

In a call to German minister Scholz, new US Treasury secretary pledges active US participation in OECD international taxation effort “to forge a timely international accord”: US Department of Treasury→

US seeks feedback on burdens of reporting foreign currency transactions: IRS / Federal Register→

Janet Yellen sworn in as US Treasury secretary

Mark Mazur confirmed as US assistant secretary for tax policy

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

US IRS solicits comments on whether treaty-based return position disclosures are burdensome: Internal Revenue Service / Federal Register→

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

US Treasury nominee Yellen would delay corporate rate increase because COVID recovery takes priority, would work with OECD to stop tax “race to the bottom”: Thomas Franck / CNBC→

Transfer pricing and the cumulative advertising effects on sales

US IRS publishes final PFIC regs (TD 9936): US Treasury / Federal Register→

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

Day 2 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

OECD adds transfer pricing country profiles for Argentina, Dominican Republic: OECD→

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others