Australia–MNE Tax

Asia-Pacific

Australia, UK agree on how to apply the arbitration provisions added via the MLI to their tax treaty: Australian Taxation Office→

June 2, 2021

Asia-Pacific

Glencore prevails in the Cobar copper transfer pricing dispute, but should it have?

June 2, 2021

New York City Economist Dr. J. Harold McClure discusses Glencore’s transfer pricing dispute with the Australian Taxation Office and assesses whether the courts reached the correct conclusions. . .

Accounting

Australia’s AASB proposes accounting rules for non-exchangeable currencies

June 2, 2021

The Australian Accounting Standards Board (AASB) on May 13 proposed to amend AASB 121 “The Effects of Changes in Foreign Exchange Rates” to provide companies guidance on accounting requirements that apply . . .

Asia-Pacific

Australia launches R&D tax incentive customer portal

May 26, 2021

The Australian Tax Office has launched a new customer portal to make it easier for companies to apply for the country’s R&D tax incentive . . .

Asia-Pacific

Australia’s High Court lets Glencore’s transfer pricing win stand

May 26, 2021

In a significant win for the taxpayer, the High Court of Australia on May 21 refused to hear an appeal of the lower court’s decision in a transfer pricing dispute between Glencore and Australia’s tax authority . . .

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Accounting

Australia’s AASB surveys literature on financial reporting by non-corporate or small entities

May 24, 2021

The Australian Accounting Standards Board (AASB) in April published Financial Reporting by Non-Corporate or Small Entities, broadly surveys the academic literature available on financial reporting by non-corporate . . .

Asia-Pacific

Australian draft guidance clarifies tax compliance for intangibles arrangements

May 19, 2021

The Australian Taxation Office set out its compliance approach to various international arrangements relating to intangible assets and the associated tax compliance risks in a draft . . .

Accounting

Australian budget includes patent box, depreciation changes

May 13, 2021

The Australian government’s 2021–2022 budget, released May 11, announces plans to encourage research through a new patent box regime and other measures and to provide broader business investment support . . .

Asia-Pacific

Australia amends permanent establishment guidance to address situations where employees are forced to remain in Australia due to COVID-19: Australian Taxation Office→

May 12, 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

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

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

Asia-Pacific

Australian tax guidance clarifies compliance with imported hybrid mismatch rules

April 21, 2021

The Australian Taxation Office issued draft guidance on April 21 regarding its assessment of compliance with the imported hybrid mismatch rules. The guidance is intended to help taxpayers prepare for compliance reviews. The imported hybrid mismatch rules aim to prevent taxpayers from entering

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Asia-Pacific

Australian court holds R&D tax offset refund was paid by mistake, subject to recovery provision

April 8, 2021

The Federal Court of Australia held on March 19 that a research & development tax offset refund claimed by, and paid to, a taxpayer, but to which the taxpayer was not entitled, is subject to . . .

Asia-Pacific

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

April 1, 2021

Asia-Pacific

Australia and Belgium enter into a memorandum of understanding on procedure for arbitration of tax disputes: Australian Taxation Office→

March 18, 2021

Asia-Pacific

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

March 15, 2021

Asia-Pacific

Australia assesses Rio Tinto AUD 406.5 million (USD 316.5 million) tax plus interest from denial of interest deduction for borrowings to pay intragroup dividend: Businesswire→

March 2, 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 . . .

Asia-Pacific

Australia says top international MNE compliance risks are profit shifting, related party debt, service hubs, inbound supply chain pricing, PE avoidance, non-arm’s length intangibles arrangements, outbound PE, foreign disposal of property: Australian Taxation Office→

February 3, 2021

Asia-Pacific

Australia confirms that compliance resources will not be used to determine existence of PE in some instances where employees are present due to COVID-19: Australian Taxation Office→

February 2, 2021

Asia-Pacific

Australian guidance addresses how investors holding hybrid securities on capital account determine market value when there is a buy-back or redemption: Australian Taxation Office→

January 22, 2021

Asia-Pacific

Final Australia targeted integrity rule addresses hybrid mismatches: Australian Taxation Office→

January 14, 2021

Asia-Pacific

Australia updates transfer pricing guidance on simplified record-keeping options: Australian Taxation Office→

December 17, 2020

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Asia-Pacific

Glencore’s Australia transfer pricing litigation – the economic considerations

December 9, 2020

Dr. J. Harold McClure, New York City, provides a detailed analysis of Glencore’s long-running transfer pricing dispute with Australia over the pricing of copper from the Cobar mines, most recently addressed by the Federal Court of Australia in a November 6 decision . . .

Asia-Pacific

Australia tax avoidance task force raises AUD 2.7 billion (USD 2 billion) in FY 2019–20

December 4, 2020

An Australian task force established to combat tax avoidance and responsible . . .

Asia-Pacific

Australia defers due date for December country-by-country report filing: Australian Taxation Office→

December 1, 2020

Asia-Pacific

Australia should change transfer pricing laws if Commissioner’s appeal of Glencore case is unsuccessful, former ATO deputy commissioner says: Jim Killaly / Tax and Transfer Policy Institute→

November 25, 2020

Australia

Australia revamps R&D taxation guidance: Minister for the Department of Industry, Science, Energy, and Resources→

November 10, 2020

Asia-Pacific

Synthesized text of Australia–Russia tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Korea tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Czech Republic tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Australia practice statement addresses interpretation of principal or main purpose tests in tax treaties: Australian Taxation Office→

October 15, 2020

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 . . .

Asia-Pacific

Australia notes noncompliance with international dealings schedule disclosures regarding hybrid mismatches (question 49): Australian Taxation Office→

September 17, 2020

Asia-Pacific

Indonesia, Australia agree to automatic exchange of tax information: Vietnam+→

September 15, 2020

Asia-Pacific

Indonesia, Australia sign agreement to exchange tax information: The Jakarta Post→

September 11, 2020

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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