Americas

Americas

Argentina extends transfer pricing deadlines due to COVID-19: AFIP (in Spanish)→

Asia-Pacific

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

Ritu Shaktawat and Rahul Jain, Khaitan & Co., discuss the High Court of Delhi’s April 22 ruling in a landmark judgment concerning the interpretation of the India-Netherlands tax treaty’s most favored nation clause . . .

Americas

Durbin, Reed, Doggett introduce bill to stop corporate inversions: Dick Durbin→

Americas

US IRS private letter ruling addresses tax consequences of multinational’s restructuring of US entities: Internal Revenue Service→

May 10, 2021

Americas

India may oppose US proposal to tax only top 100 companies: Dilasha Seth / Business Standard→

May 10, 2021

Americas

Global deal on MNE tax reform likely by October, Saint-Amans tells the French Senate’s finance committee: Reuters→

May 10, 2021

Digital Economy

UK supports Biden’s global tax deal proposal, with caveats

May 6, 2021

The UK’s primary interest in international tax talks is addressing digital taxation and the allocation of taxing rights under the OECD’s “Pillar One,” but it is okay with the US’s not-digital-only approach to Pillar One, according to Mike Williams . . .

Americas

US solicits comments on burdens related to completing a return by a US transferor of property to a foreign corporation: Internal Revenue Service / Federal Register→

May 6, 2021

Americas

Professor breaks down US strategy in Pillar 1 & 2 negotiation: Michael P. Devereux / Oxford→

May 6, 2021

Global minimum tax agreement will require substance-based carve-out, Saint-Amans says

May 5, 2021

To reach international agreement, a global minimum tax deal would need to exclude from minimum taxation income from substantive activities within a jurisdiction, according to Pascal Saint-Amans . . .

Americas

Danish High Court rules on beneficial ownership of dividends for tax purposes

May 5, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a highly-anticipated High Court of Eastern Denmark ruling issued May 3 that resolves two tax disputes concerning beneficial ownership . . .

Europe

Finnish court decisions on tax neutral mergers with US companies may have positive implications for shareholders in other EU states

May 5, 2021

Marianna Santamala, Bird & Bird Attorneys Ltd, discusses two recent Finnish Supreme Administrative Court decisions that may have a wider impact on shareholders located in the European Union . . .

More News

US senators query whether former attorney general Barr stalled Caterpillar tax investigation

May 4, 2021

US Senate Finance Committee Chair Ron Wyden, D-Ore., and Senator Sheldon Whitehouse, D-R.I., launched an investigation on April 28 into whether Trump administration interference stalled a tax investigation of Caterpillar . . .

Accounting

New US tax schedules allow enhanced international tax reporting for pass-throughs

May 4, 2021

The US Treasury Department and the IRS, on April 30, released early release drafts of redesigned schedules K-2 and K-3 for forms 1065, 1120-S, and 8865 for tax year 2021 . . .

Asia-Pacific

Global minimum tax opponents will not stop agreement, Saint-Amans says

May 4, 2021

Negotiations on a global minimum tax on corporations have the momentum that they need to reach an agreement now that France, Germany, and others have signaled support for recent US proposals. . .

Americas

Switzerland rejects Biden’s tax haven claim: swissinfo.ch→

May 3, 2021

Americas

Bermuda leaders chafe at Biden’s tax haven label: Scott Neill / The Royal Gazette→

May 3, 2021

Accounting

FASB council considers cash flow statement, financial performance reporting changes

May 3, 2021

Members of the Financial Accounting Standards Advisory Council (FASAC) expressed support for certain improvements to cash flow statements in an April 8 meeting in which they discussed the importance for FASB to improve various financial reporting areas . . .

Americas

British Virgin Islands extends deadlines for CbCR, CRS, and FATCA reporting due to technical difficulties: Virgin Islands National Tax Authority→

April 29, 2021

Americas

Biden plan would raise US MNE taxes by 81 percent, create incentives for profit shifting out of the US, think tank concludes: Cody Kallen / Tax Foundation→

April 29, 2021

Americas

Biden’s American Families Plan proposes additional IRS funds to scrutinize large corporation taxes: The White House→

Africa

UN updates transfer pricing manual for developing countries

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

GOP infrastructure counterproposal would seek to avoid corporate and international tax hikes through smaller plan and reallocated spending: Minority, US Senate Committee on Environment and Public Works→

Digital Economy

US state of Connecticut considers digital advertising tax with international implications similar to state of Maryland’s: Connecticut General Assembly →

Americas

Wyden touts plan to replace “hodgepodge” of oil and gas tax incentives with clean energy producer breaks: United States Senate Committee on Finance→

Americas

French and German finance ministers voice support for US proposal on global minimum tax: Reuters→

Americas

Google UK reports its 2020 financials: the transfer pricing implications

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Americas

Brazil’s Supreme Court addresses software taxation

Francisco Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados and Rachel Mira Lagos, Bocater Advogados, discuss a important Brazilian Federal Supreme Court ruling on software taxation . . .

Americas

Mexico amends tax rules on outsourcing, insourcing services

Arturo Treviño Villarreal, Fratelli Consultores, discusses Mexico’s April 23 guidance covering tax rules for outsourcing and insourcing . . .

Carbon Tax

Biden looking into carbon border adjustment tax like one under consideration in EU, John Kerry says: Yahoo Finance→

April 26, 2021

Americas

Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

Americas

US Treasury Secretary Yellen says tax moves needed to help tackle climate change

US Secretary of the Treasury Janet L. Yellen spoke on April 21 of the Biden administration’s “whole-of-government approach” to aggressively tackling climate change – including creating a targeted investment tax credit . . .

Americas

Google UK paid just £50 million (69.14 million USD) in corporate tax last year, despite posting £1.8 billion (2.49 billion USD) of revenues: Chris Newlands / inews→

Americas

Brazil proposal would enhance tax incentives for technology R&D