China–MNE Tax

Americas

What every taxpayer should learn from Coca-Cola: Song / CrossBorder Solutions→

March 3, 2022

Africa

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

February 28, 2022

Asia-Pacific

China uses big data to crack down on multinational companies involved in tax evasion

February 8, 2022

Hengka (Henry) Ji and Zihan Zhang, Zhong Lun Law Firm, discuss China’s January 26 announcement that tax authorities across the country will begin to rely more on big-data analytic resources to detect tax evasion by big businesses and individuals.

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Americas

Asia to see disparate impacts from global digital tax reforms, IMF reports

September 15, 2021

Global tax reform efforts to address digitalization of the economy would likely have modest revenue effects in Asia, on the whole, according to a September 14 report from the International Monetary Fund; however, the effects would be uneven . . .

Americas

US R&D tax incentives will be among least generous unless Congress acts, study finds

September 8, 2021

The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a September 7 study from . . .

Americas

Japan releases study group report on international taxation in the digital economy

August 19, 2021

Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .

Asia-Pacific

China simplifies application procedure for unilateral advance pricing arrangements

August 17, 2021

Grace Lin, Cuatrecasas, discusses China’s new simplified procedure for applying for a unilateral advance pricing arrangement (APA), which was announced in Notice No. 24/2021 on July 30 and will be implemented from . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

China

China may not have much to lose under global corporate minimum tax and could hinge its support on US’s willingness to lift tariffs on Chinese goods: Frank Tang / South China Morning Post→

June 21, 2021

Asia-Pacific

China increases tax relief for science and technology companies

June 21, 2021

Hengka (Henry) JI and Jiannan Zhu, Zhong Lun Law Firm, discuss Chinese government announcements issued March 16 – April 15 implementing tax policies promoting scientific and technological innovation and the development . . .

Americas

US Senate approves bill with R&D funding for semiconductor industry

June 17, 2021

The US Senate passed with bipartisan support on June 8 a bill that would authorize new funding for research and development (R&D) to boost . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Asia-Pacific

China cancels export VAT refund for iron and steel products

June 3, 2021

Grace Lin, Cuatrecasas, discusses Chinese government guidance, applicable May 1, on the export VAT refund for iron and steel products . . .

Asia-Pacific

South Korea expands R&D tax breaks to bolster semiconductor industry

June 2, 2021

The Republic of Korea signaled its intention to heavily boost its semiconductor industry with an announcement on May 13 that it will offer up to 50 percent tax credits on research and development (R&D) investment and up to 20 percent . . .

Americas

Key US Republican draws lines for global tax deal

May 26, 2021

US Senator Mike Crapo (R-Idaho) sent Treasury Secretary Janet Yellen a letter on May 24 outlining potential terms that he would consider acceptable in a global tax deal . . .

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 . . .

Asia-Pacific

China maintains tariff and import tax incentives for certified foreign R&D centers

May 17, 2021

Grace Lin, Cuatrecasas, discusses the Chinese government’s two April notices announcing new tariff and import tax policies to support technology innovation under the 14th Five-Year Plan . . .

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. . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

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

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

April 22, 2021

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 . . .

Asia-Pacific

China guidance addresses new tariff and tax incentives for integrated circuit, software industries

April 20, 2021

Grace Lin, Head of Tax, Cuatrecasas, Shanghai, discusses the Chinese government’s issuance in March of two notices clarifying tariff and tax incentives for the circuit and software industries . . .

Americas

US confident “vast majority” of developed nations will approve global minimum tax, US deputy treasury secretary says: Thomas Franck / CNBC→

April 14, 2021

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Asia-Pacific

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

April 9, 2021

Asia-Pacific

China enhances R&D super deduction for manufacturing, extends multiple tax breaks for doing business in China

April 6, 2021

Hengka (Henry) JI, Zhong Lun Law Firm, discusses the March 15 release by China’s Ministry of Finance and State Administration of Taxation of “Announcement No. 6 of 2021 Concerning the Extension of Several Preferential Tax Policies”. . .

Asia-Pacific

China simplifies unilateral advance pricing arrangement procedures for some taxpayers

April 1, 2021

Agnes Lo, Lingnan University, and Raymond Wong, City University of Hong Kong, discuss China’s State Taxation Administration’s March 19 guidance simplifying unilateral advance pricing arrangement procedures for some taxpayers. . .

Asia-Pacific

China to increase extra tax deduction for R&D expenses of manufacturing firms: State Council→

March 26, 2021

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Asia-Pacific

China should consider new tax on tech companies, securities regulation official and former vice finance minister say: Cheng Siwei, YU Hairong, Zhang Erchi, and Denise Jia / Nikkei Asia→

January 20, 2021

Asia-Pacific

China official says governments should consider levying digital taxes on online platforms because users created the value and should share in the profits: Reuters→

December 16, 2020

Asia-Pacific

China signed 21 advance pricing arrangements in 2019, report shows

November 17, 2020

Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong, and Raymond Wong, Associate Professor, City University of Hong Kong, discuss an October 29 report issued by China’s State Taxation Administration that provides statistics on China’s advance pricing arrangement program through 2019 . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

OECD publishes tax information exchange reviews for Anguilla, Chile, China, Gibraltar, Greece, Korea, Malta, Papua New Guinea, Uruguay: OECD→

September 3, 2020

Asia-Pacific

China seeks tax treaty with Norway, official says: Ministry of Foreign Affairs of the People’s Republic of China→

September 1, 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

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