Japan–MNE Tax

Africa

Belize and Cameroon deposit instruments of ratification for BEPS MLI with the OECD; entry into force is August 1, for both countries; Japan extends the application of the multilateral BEPS convention: OECD→

April 21, 2022

Africa

Japan-Morocco income tax treaty to enter into force on April 23, 2022: Japanese Ministry of Finance→

March 25, 2022

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 . . .

Asia-Pacific

Japan 2022 tax plan adopts tax incentives to boost employee pay through new deductions for companies that increase wages; declines to adopt capital gains tax hike or carbon tax: Nikkei Asia

December 14, 2021

Asia-Pacific

Japan–Serbia tax treaty to enter into force

November 8, 2021

The governments of Japan and Serbia on November 5 completed the necessary exchange of diplomatic notes for the entry into force of the tax treaty between the two countries that was signed in July 2020 and will generally have effect beginning in . . .

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

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

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 . . .

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

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 . . .

Asia-Pacific

Japan and Switzerland sign tax treaty protocol

July 16, 2021

Japan and Switzerland on July 16 signed an amending protocol to the tax treaty between the countries that would revise the treatment of taxes on investment income, among . . .

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 . . .

Americas

Japan–Uruguay tax treaty enters into force July 23

June 24, 2021

The tax treaty signed by the governments of Japan and Uruguay on September 13, 2019, will enter into force. . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Georgia

Japan–Georgia tax treaty signed January 29 will enter into force on July 23 following June 23 exchange of diplomatic notes: Japan Ministry of Finance→

June 23, 2021

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 . . .

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

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 . . .

Asia-Pacific

Japan enacts corporate, income, inheritance tax reforms

May 26, 2021

Takato Masuda of Nishimura & Asahi discusses Japanese corporate, income, and inheritance tax reforms enacted March 26 . . .

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 . . .

Azerbaijan

Japan, Azerbaijan to begin negotiations May 20 for new tax treaty to replace 1986 treaty: Japan Ministry of Finance→

May 19, 2021

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 . . .

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 . . .

Americas

US IRS shortened completion time for advance pricing agreements in 2020 but backlog remains

March 31, 2021

The US IRS cut the median time to complete advance pricing agreements (APAs) down to 32.7 months in 2020, a drop of over six months from last year, its best completion time in five years, IRS statistics published on March 30 reveal. . .

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Asia-Pacific

Japanese ministry considers reducing tax burden on Japanese-based tech companies’ overseas earnings: The Mainichi→

March 17, 2021

Asia-Pacific

Japanese ministry to assemble panel of experts to analyze taxation of digital economy: Japan Ministry of Economy, Trade, and Industry (In Japanese)→

March 3, 2021

Asia-Pacific

Japan considers new carbon tax on emissions: Jiji Press→

March 1, 2021

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Asia-Pacific

Japan-Spain tax treaty to enter into force in May

February 19, 2021

Japan and Spain recently completed the necessary steps . . .

Asia-Pacific

Japan, Switzerland agree to amend tax treaty

February 8, 2021

The government of Japan and the Swiss Federal Council have agreed in . . .

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

Japan, Switzerland to negotiate tax treaty amendments

December 15, 2020

Japan’s Ministry of Finance today announced that the government of Japan and the Swiss . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Asia-Pacific

Japan, Georgia commence tax treaty negotiations: Japan Ministry of Finance→

October 15, 2020

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 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

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