Asia-Pacific

New Zealand provides Covid-19 transfer pricing guidance

September 16, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP, New Zealand, discuss recently released New Zealand Inland Revenue transfer pricing guidance for businesses affected by Covid-19 . . .

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

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Asia-Pacific

Australian guidance addresses treatment of capital gains in computing foreign income offset limit: Australian Taxation Office→

September 8, 2020

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

Asia-Pacific

Singapore advance ruling addresses tax issues relating to foreign partnership: Inland Revenue Authority of Singapore→

September 4, 2020

Asia-Pacific

Singapore summarizes advance ruling on tax treatment of distributions from subordinated perpetual securities: Inland Revenue Authority of Singapore→

September 4, 2020

Africa

Leaked OECD draft pillar one and pillar two digital tax blueprints available

September 3, 2020

McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints . . .

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

September 3, 2020

Africa

Taxing somewhere, no matter where: what is the GLoBE proposal really about

September 2, 2020

Dr. Leopoldo Parada a lecturer at the University of Leeds School of Law, UK, makes the case for rejecting the global anti-base erosion proposal, also known as “GloBE,” introduced into the international tax debate by the OECD . . .

Asia-Pacific

Israel seeks to negotiate tax treaty with UAE: Hamodia→

September 1, 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

Asia-Pacific

The Korean tax authorities’ challenge to Netflix’s transfer pricing

September 1, 2020

Dr. Harold McClure, a New York City economist, notes the Korean National Tax Service’s August 27 announcement that it is investigating the transfer pricing practices of 21 multinationals, including US technology and media multinational, Netflix, and considers what the tax service’s transfer pricing dispute with Netflix might be. . .

Asia-Pacific

Japan considers tax reform to lure foreign financial firms, annual policy says: Reuters→

August 31, 2020

Asia-Pacific

Hong Kong, Serbia enter into tax agreement

August 28, 2020

Hong Kong and Serbia have signed an agreement designed to help their residents avoid . . .

Asia-Pacific

Switzerland Federal Council approves tax treaty with Bahrain, amendments to Kuwait tax treaty

August 28, 2020

The Swiss Federal Council on August 26 adopted laws approving a new . . .

Asia-Pacific

South Korean tax office investigating Netflix over “phantom” management fees paid to US headquarters: Yonhap News Agency→

August 27, 2020

Asia-Pacific

MasterCard’s application before India’s High Court: the equalisation levy dilemma!

August 25, 2020

Ashish Sodhani, Leader, International Tax, at Nishith Desai Associates, Mumbai, discusses the Delhi High Court’s August 18 ruling on MasterCard’s petition to stay payment of the equalisation levy. . . .

Americas

India’s Google tax contributes 1% of direct tax in IT hubs of Bengaluru and Hyderabad despite expansion to online e-commerce: Shrimi Choudhary / Business Standard News→

August 25, 2020

Asia-Pacific

Australian government advises that it will ask large entities to confirm information to be disclosed in legislatively mandated corporate tax transparency report next month: Australian Taxation Office→

August 25, 2020

Africa

The revised operating lease accounting standards: what are the implications for transfer pricing?

August 24, 2020

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Asia-Pacific

Australian alert addresses multiple entry consolidated groups that avoid capital gains tax through transfer of assets to an eligible tier-1 company prior to divestment: Australian Taxation Office→

August 24, 2020

Americas

US notifies Hong Kong of intent to terminate agreement allowing international shippers to avoid double tax: US Department of State→

August 21, 2020

Asia-Pacific

Malaysia updates tax guide for foreign digital services providers: Royal Malaysian Customs Department→

August 21, 2020

Asia-Pacific

Oman State Council proposes draft income tax amendments allowing for exchange of tax information with other countries consistent with international agreements: Times Of Oman→

August 21, 2020

Asia-Pacific

Hong Kong-Macao tax arrangement enters into force

August 21, 2020

Hong Kong’s Inland Revenue Department on August 21 announced that an arrangement with Macao for the avoidance of double taxation entered into . . .

Asia-Pacific

Draft Australian transfer pricing guidance addresses interest-free loans, debt vs. equity conundrum

August 19, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP, discuss August 12 draft transfer pricing guidance issued by the Australian Taxation Office outlining its proposed risk assessment of outbound interest-free loans made to related parties . . .

Asia-Pacific

India publishes synthesized text of tax treaty with Ukraine adding MLI changes: Government of India Income Tax Department→

August 19, 2020

Asia-Pacific

Singapore proposes to strengthen GAAR, introduce tax avoidance surcharge

August 19, 2020

Eugene Lim and Janus Lim, Taxise Asia LLC (WTS Global member), discuss a Singapore government proposal that would reinforce and clarify the general anti-avoidance rule (GAAR) regime and introduce a new surcharge on tax avoidance . . .

Americas

Japan, Jamaica tax treaty to enter into force, ministry says

August 18, 2020

Japan’s Ministry of Finance today announced that the Japanese . . .

Asia-Pacific

Australia issues tax guidance on thin capitalization limitations

August 18, 2020

Dr. Harold McClure, a New York City economist, discusses August 12 guidance issued by the Australian Taxation Office that limits intercompany interest deductions . . .

Asia-Pacific

Hong Kong updates tax guidance to reflect new laws on taxation of royalties, other IP income: Inland Revenue Department→

August 13, 2020

Asia-Pacific

Taiwan outlines procedure for obtaining tax treaty benefits, notes entry into effect of Czech-Taiwan tax treaty: Taiwan Ministry of Finance→

August 12, 2020

Asia-Pacific

India issues comprehensive guidance on cross-border tax dispute resolution

August 11, 2020

Ritu Shaktawat, Partner, and Raghav Kumar Bajaj, Principal Associate, at Khaitan & Co, Mumbai, discuss India guidance, released August 7, on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations . . .

Asia-Pacific

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

August 10, 2020

Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .

Asia-Pacific

Trump trade adviser Peter Navarro says tax incentives in Ireland, Singapore, Switzerland, India, China that lure pharmaceutical manufacturing away from US are a “significant” problem: Brian O’Donovan / RTÉ→

August 10, 2020

Asia-Pacific

Israel considers requiring taxpayers to pay disputed tax or transfer pricing assessments pending appeal

August 10, 2020

Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher of JH Consulting Ltd., Tel Aviv-Yafo, discuss an Israeli proposal to require immediate tax collection if a taxpayer appeals a tax or transfer pricing controversy in district court . . .

Asia-Pacific

Malaysia publishes guide on digital services tax for foreign service providers: Royal Malaysian Customs Department Internal Tax Division→

August 7, 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.
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