Americas

The US IRS, in Announcement 2020-40, has advised that the . . .

Africa

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

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

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

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

Americas

Cayman Islands to propose changes to pending LLP law to improve its “commercial functionality” prior to the regime becoming operational: Cayman Finance→

October 16, 2020

Americas

Colombia publishes MAP guidance for resolution of tax treaty disputes

October 15, 2020

Juana Obando, Transfer Pricing Associate at BaseFirma Colombia, discusses August 21 Colombian tax authority guidance on the procedure to request the resolution of cross-border tax disputes under Colombia’s tax treaties . . .

Americas

France reinstates digital tax, courting trade war: Bjarke Smith-Meyer & Elisa Braun / POLITICO→

October 14, 2020

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 . . .

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

Americas

US corrects final tax regs on income subject to a high rate of foreign tax: Department of Treasury / Federal Register→

October 9, 2020

Americas

US IRS issues final BEAT regulations: Department of Treasury→

October 9, 2020

Americas

Peru postpones some country-by-country report submissions

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses September 28 Peru guidance which alters the procedure for the submission of country-by-country reports on multinational group entities . . .

Americas

Cayman Islands Premier welcomes island’s removal from EU tax blacklist: Ministry of Financial Services, Cayman Islands →

Americas

Barbados appalled at EU’s “unjust” and “disproportionate” decision to list the Island as a non-cooperative jurisdiction for tax purposes, Prime Minister says: NationNews→

Americas

US IRS issues final regs on withholding and information reporting for dispositions of partnership interests engaged in US trades or businesses: US Treasury→

Africa

COVID-19 test producer Qiagen’s intercompany financing – the transfer pricing issues

October 6, 2020

Dr. Harold McClure, a New York City Economist, discusses an analysis by Vincent Kiezebrink and Jasper van Teeffelen which accuses biotech firm Qiagen of base erosion through the use of intercompany loans . . .

Africa

Australia to change to corporate tax residency test

October 6, 2020

The Australian government will propose to change the corporate residency test used to determine if a company incorporated offshore is liable for income tax in Australia, budget documents released today . . .

Americas

New US IRS practice unit training materials address cost-sharing arrangements and stock-based compensation: US Department of the Treasury→

October 5, 2020

Americas

Pillar 2 negotiations could result massive increase in global tax and compliance costs, undermining COVID-19 recovery efforts, US advocacy group says: Peter Sepp / National Taxpayers Union→

October 5, 2020

Americas

US IRS advises taxpayers to exit abusive micro-captive insurance schemes, will target variations of abuse identified in Notice 2016-66: IRS→

October 1, 2020

Americas

California governor vetoes bill requiring the Franchise Tax Board to disclose to the legislature of large corps’ gross receipts, tax liabilities, tax credits: Chirs Micheli / California Globe→

October 1, 2020

Americas

US issues final regs on gain or loss of foreign persons from sale or exchange of partnership interests [TD 9919]: US Treasury→

Americas

US issues tax regs on source of income from certain sales of personal property including inventory by nonresidents attributable to a US fixed place of business [TD 9921]: US Treasury→

Americas

US issues proposed foreign tax credit regs [REG-101657-20]: US Treasury→

Americas

US issues final and temporary foreign tax credit regs [TD 9922]: US Treasury→

Americas

US corrects FDII and GILTI regs: Federal Register→

Americas

Peru and Japan: the road to a double tax treaty

September 28, 2020

Franz Salazar Anccasi, Tax Advisory Manager at Edwards Peru, Lima, Peru, discusses the status of a tax treaty being negotiated by Japan and Peru . . .

Americas

OECD, Brazil tax officials provide update of transfer pricing alignment project

September 28, 2020

Francisco Lisboa Moreira a tax partner at Bocater Advogados, São Paulo, Brazil, discusses a recent conference where senior OECD and Brazil tax officials provided an update on efforts to align Brazil’s transfer pricing laws with global standards . . . .

Americas

US IRS corrects final regs on limitations dividends received deduction: Federal Register→

September 25, 2020

Americas

Panama introduces EMMA tax regime to attract multinational manufacturers

September 25, 2020

Laura Pinilla, an associate at BaseFirma Colombia, discusses new Panama tax incentives for multinationals signed into law on August 31 . . .

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

September 25, 2020

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Americas

US IRS issues proposed regs that modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under section 367(a): Federal Register→

Americas

US IRS publishes final regs on ownership attribution for determining CFC or US shareholder status: Federal Register→

Americas

EU leaning towards appealing Apple tax decision, unnamed senior tax officials say, deadline to appeal is Sept. 25: Simon Van Dorpe / Politico→

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available