Asia-Pacific

Taiwan offers foreign businesses advance rulings on tax liability

January 4, 2021

Taiwan’s tax authority on January 4 announced that foreign businesses that do not have a . . .

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

January 4, 2021

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Asia-Pacific

Hong Kong, Serbia tax agreement enters into force

January 4, 2021

A comprehensive agreement providing for the avoidance of double taxation entered into force between Hong Kong . . .

Asia-Pacific

New Zealand hits Oracle with NZ 20.3M (USD 14.4M) in transfer pricing assessments: Rob O’Neill / New Zealand Reseller News→

December 23, 2020

Asia-Pacific

Energy giant Cairn wins Rs 8,000 crore (USD 1.2 billion) arbitration award in dispute with India over taxation of indirect transfer of assets: Dilasha Seth / Business Standard→

December 23, 2020

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Practical obstacles prevent low-income countries from participating in global tax standard-setting through Inclusive Framework, authors say: Rasmus Corlin Christensen, Martin Hearson, & Tovony Randriamanalina / The International Centre for Tax and Development→

December 21, 2020

Asia-Pacific

Germany and Pakistan deposit instruments of ratification for BEPS MLI with the OECD, joining 57 other countries; entry into force is April 1, 2021, for both countries: OECD→

December 21, 2020

Asia-Pacific

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

December 17, 2020

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

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

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

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020

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

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

December 15, 2020

Asia-Pacific

Singapore updates guidance on law providing for nontaxation of gain on disposal of equity investments through 2027: Inland Revenue Authority of Singapore→

December 14, 2020

Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

December 14, 2020

Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→

December 11, 2020

Africa

Transactional profit indicators for the TNMM are not viable

December 9, 2020

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

December 9, 2020

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

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 . . .

88% of countries engaging in automatic exchange of financial account information have satisfactory legal frameworks, Global Forum peer review concludes: OECD→

December 9, 2020

Asia-Pacific

Hong Kong issues new guidance on tax concessions for ship leasing: Inland Revenue Department→

December 7, 2020

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

India expected to challenge Vodafone’s arbitration award in dispute involving taxation of indirect transfer of assets: Timsy Jaipuria / cnbctv18.com→

December 4, 2020

Africa

OECD toolkit helps developing country tax administrations satisfy confidentiality and data security requirements for automatic exchange of information with other countries: OECD→

December 2, 2020

Asia-Pacific

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

December 1, 2020

Asia-Pacific

Thailand clarifies transfer pricing rules for using internal and external comparables

December 1, 2020

Andrew Jackomos, Co-Managing Partner, and Rohit Sharma, Principal, Transfer Pricing, at HLB Thailand, discuss a November 6 Thailand regulation prescribing the approach that Thai tax officers should take when analyzing and adjusting the pricing of transactions between related parties . . .

Africa

Shell releases 2019 country-by-country report disclosing revenue, profits, tax paid in 98 countries: Shell.com→

November 30, 2020

Asia-Pacific

Taiwan clarifies APA request procedures when taxpayer changes its business address after application submitted: Taiwan Ministry of Finance→

November 30, 2020

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

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

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

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 . . .

Transfer Pricing

UAE launches country-by-country reporting platform: Gulf News→

November 17, 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 . . .

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 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