Americas

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

American Samoa

EU Council keeps 9 jurisdictions on `harmful’ tax practices blacklist: American Samoa, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands and Vanuatu: Council of the European Union→

February 25, 2022

Americas

The road to audit-proof transfer pricing documentation: Song / CrossBorder Solutions→

February 24, 2022

Americas

Apple v. European Commission: Outcome could strengthen or weaken Commission’s success in challenging lack of arm’s length principles in TP methods through state aid concerns: Cantley and Dietrich / SSRN→

February 24, 2022

Americas

The applicability of the Spanish GAAR to conduit structures after the CJEU Danish cases

February 23, 2022

Aitor Navarro, Carlos III University, discusses the Spanish tax authorities’ December 16, 2021 publication of a panel report on the applicability of the domestic GAAR to a conduit arrangement aimed at benefiting from an exemption at source on the payment of interest income to EU residents.

Accounting

Income tax provision: what’s the rush about?: Cavanaugh / CrossBorder Solutions→

February 23, 2022

Americas

USTR prods Canada to scrap digital services tax: Office of the US Trade Representative→

February 23, 2022

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

February 22, 2022

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

Americas

Netherlands, Colombia sign income tax treaty: Geis / Commentary Box Sports→

February 18, 2022

Americas

Largest MNEs can’t comply with requirements to track their transactions under OECD tax deal’s draft revenue sourcing rules, USCIB says: McDonald and Minor / USCIB→

February 18, 2022

Americas

US Senate Finance Committee Republicans write US Treasury Secretary with `alarming’ concerns over OECD tax plans: Crapo / US Senate Committee on Finance→

February 17, 2022

Accounting

All about deferreds: Cavanaugh / CrossBorder Solutions→

February 16, 2022

Americas

Mexico’s 2022 income tax law takes effect, incorporates notable transfer pricing changes

February 14, 2022

Francisco Arballo, Grupo Consultor EFE, discusses Mexico’s 2022 income tax law, which went into effect in January, incorporating several amendments the Mexican legislature proposed in September 2021, including various changes in transfer pricing.

Americas

IRS answers research credit claims (section 41) on amended returns: Internal Revenue Service→

February 11, 2022

Americas

Trinidad and Tobago: Court of Appeal quashes treaty shopping scheme

February 9, 2022

Allan Lanthier, a former advisor to the Canadian government, analyzes the recent treaty shopping decision of Trinidad and Tobago’s Court of Appeal – a decision that stands in stark contrast to the recent treaty shopping decision of the Supreme Court of Canada in the Alta Energy case.

Accounting

Bridging the gap between tax and accounting rules: Cavanaugh / CrossBorder Solutions→

February 9, 2022

Americas

Mexico says adios to advanced pricing agreements for maquiladoras: CrossBorder Solutions→

February 7, 2022

Americas

US House passes chips funding bill, could provide US $52 billion in R&D, production funding for semiconductor companies in US: Secard / Industry Week→

February 7, 2022

Americas

Build Back Never?

February 3, 2022

It was an end-of 2021 cliffhanger: Throughout the fall, Build Back Better was gaining momentum, making headlines, and finally, in November, passing through the House in a 220-213 vote. It had just one more hurdle: to pass through the Senate. Now that is looking increasingly unlikely.

Americas

Paraguay requires new transfer pricing section on income tax return

January 31, 2022

Francisco Arballo, Grupo Consultor EFE, discusses Paraguay’s December 30, 2021 publication of a new income tax return format, including a new section differentiating the transfer pricing adjustments made to intercompany transactions based on the sixth method, which is . . .

Accounting

What do you need to know about the valuation allowance? Telson / CrossBorder Solutions→

January 28, 2022

More News

The IRS’s new R&D documentation demands: CrossBorder Solutions→

January 26, 2022

Americas

US Senate Finance Chair looking into pharma international tax abuse

January 19, 2022

Pharmaceutical industry tax practices involving the use of offshore subsidiaries to avoid paying US taxes are the target of an investigation by US Senate Finance Committee Chair Ron Wyden (D-Ore.), who requested information from Bristol Myers Squibb on January 18; this latest information request follows a similar letter sent to . . .

Americas

Colombian regulation addresses ultimate beneficial owner report for tax purposes

January 18, 2022

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian tax administration’s implementation of a regulation on the registration of the ultimate beneficial owner-report for tax purposes, which entered into force on January 15, and establishes . . .

Americas

Poland transfer pricing laws under review to strengthen system against tax evasive behavior

January 14, 2022

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s participation since November in a project coordinated by the European Commission to reform Polish transfer pricing regulations; the project is planned to . . .

Americas

Switzerland will implement global minimum tax by constitutional amendment

January 13, 2022

The Swiss Federal Council on January 12 decided that it will implement the 15% global minimum tax agreed by the OECD Inclusive Framework through a constitutional amendment with an aim to ensure the measure comes into force as of January 1, 2024; the approach is intended to . . .

Africa

Swiss international tax update addresses OECD deal, treaties, MAP

January 12, 2022

Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .

Americas

Barbados country-by-country reporting tax law takes effect

January 12, 2022

Barbados tax legislation enacting country-by-country reporting came into operation on December 31, 2021, following publication in the Official Gazette on . . .

Africa

EU tax transparency directive: When turkeys vote for Christmas

January 10, 2022

Cédric Maheo, CWA Morocco, discusses how the EU directive on public country-by-country reporting for large multinationals, published in the Official Journal of the European Union on December 1, will give tax authorities in the developing world new data on multinationals operating in . . .

Accounting

OECD’s ‘complex’ minimum tax rules have ‘major policy issues,’ BIAC says

January 7, 2022

In a January 6 letter to the OECD, business advisory group Business at OECD (BIAC) criticizes “significant policy inconsistencies” in the OECD’s global minimum tax model rules that it considers “potentially fatal” to their operation; moreover, it contends efforts must be made to . . .

Americas

US IRS extends time to fix R&D tax credit claims under new requirements

January 6, 2022

The Internal Revenue Service will give taxpayers a little more time to “perfect” research and development (R&D) tax credit claims that fall short of new information requirements, according to a January 5 IRS update . . .

Americas

US IRS explains tax rules for dividends received deduction for foreign income

January 4, 2022

A US Internal Revenue Service “practice unit” released January 4 offers an overview of the rules relating to the dividends received deduction for certain foreign income of US corporations under Internal Revenue Code section 245A . . .

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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