Asia-Pacific

Americas

Whirlpool’s maquiladora: the Mexican transfer pricing perspective

June 3, 2020

Dr. Harold McClure, a New York economist, discusses transfer pricing issues with respect to Whirlpool’s Mexico affiliate, which conducted toll manufacturing operations on behalf of a Luxembourg affiliate, as described in the recent Tax Court case, Whirlpool Financial Corporation v. Comr. . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Asia-Pacific

New Malaysian guidelines clarify tax rules for determining “place of business”: LHDN Malaysia→

June 2, 2020

Asia-Pacific

Tax guidance addresses mischaracterized arrangements and schemes connected with foreign investment into Australian entities: Australian Taxation Office→

May 29, 2020

Asia-Pacific

Thailand offers tax incentives to promote foreign investment: KPMG →

May 27, 2020

Africa

Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches

May 26, 2020

Hugo Chary and Thibaut Roques of TP qube, Paris / Bordeaux, France, discuss how to adjust comparable company searches to reflect the new market conditions that have arisen from the COVID-19 crisis . . .

Asia-Pacific

Philippine senator proposes tax on digital content, advertising, online marketplaces: The Star→

May 21, 2020

Africa

Countries still can’t agree on update to multinational group taxation rules, OECD official says

May 21, 2020

The 137 countries that make up the “Inclusive Framework on BEPS” are having a difficult time reaching agreement on an update to the global rules for allocating multinational group profits among nations, according to Pascal Saint-Amans, OECD Center for Tax Policy and Administration. Saint-Amans warned. . .

Asia-Pacific

Hong Kong government advances Hong Kong-Macao tax treaty: Inland Revenue Department→

May 20, 2020

Asia-Pacific

Australia updates GAAR guidance: Australian Taxation Office→

May 20, 2020

Americas

US and lawmakers and officials to propose tax breaks to encourage companies to move operations out of China: Reuters→

May 20, 2020

Asia-Pacific

Saudi Arabia to triple VAT rate to 15 percent, suspend cost of living allowance: BBC News→

May 15, 2020

Asia-Pacific

India amends rules for resolution of tax disputes under MAP

May 15, 2020

Ritu Shaktawat, a partner at Khaitan & Co., Mumbai, discusses May 6 India government amendments to the rules for accessing the mutual agreement procedure (MAP) in tax treaties . . .

Asia-Pacific

BEPS MLI to enter to force for Czech Republic, Korea

May 13, 2020

The OECD today announced that the Czech Republic and Korea have deposited their . . .

Asia-Pacific

Synthesized text of Australia-Norway tax treaty as modified by BEPS MLI published: Australian Taxation Office→

May 13, 2020

Asia-Pacific

India clarifies tax residency of ‘visiting’ individuals stuck in lockdown

May 12, 2020

Ritu Shaktawat a partner at Khaitan & Co, Mumbai, India discusses an Indian government tax circular issued on May 8 providing relief to individuals that needed to prolong their stay in India due to the COVID-19 emergency . . .

Asia-Pacific

US Chamber, 8 other lobbying groups urge India to delay equalisation levy: Aditya Kalra / Reuters→

May 6, 2020

Asia-Pacific

Indonesia joins BEPS MLI to fight tax avoidance

May 4, 2020

Indonesia on April 28 deposited its instrument of ratification for . . .

Asia-Pacific

Hong Kong revises guidance on advance tax rulings

April 29, 2020

Agnes Lo of Lingnan University and Raymond Wong, City University of Hong Kong discuss Hong Kong Inland Revenue Department guidance issued April 16 on advance tax rulings . . .

Asia-Pacific

US trade report says India’s equalisation levy impedes trade, risks retaliation: Kirtika Suneja / The Economic Times→

April 29, 2020

Asia-Pacific

Synthesized text of Ireland-Singapore tax treaty as amended by MLI released: Irish Revenue→

April 29, 2020

Asia-Pacific

Pakistan income tax collection from services falls 20 percent in March: Shahnawaz Akhter / The News→

April 28, 2020

Asia-Pacific

China temporarily halts interest on late import tax payments for foreign firms operating in special economic zones: Bloomberg Tax→

April 22, 2020

Asia-Pacific

India’s new 2 percent equalisation levy on the digital economy enters into force

April 22, 2020

Vinita Krishnan and Jugal Mundra, Khaitan & Co, Mumbai, discuss in detail India’s new 2 percent equalisation levy, which became effective on April 1 and applies to a broad range of nonresident e-commerce sales and services to Indian customers . . .

Africa

Denmark denies coronavirus aid to companies registered in countries on EU list of noncooperative tax jurisdictions: Nikolaj Skydsgaard / Reuters→

April 21, 2020

Africa

US tax policy nonprofit tracks worldwide COVID-19 tax relief: Tax Foundation→

April 17, 2020

Asia-Pacific

New South Korea transfer pricing and diverted profits tax laws enter into effect

April 16, 2020

Jay Shim and Steve Minhoo Kim of Lee & Ko, South Korea, discuss important amendments to South Korea’s international tax and transfer pricing laws that became effective on January 1 including a Korean version of a diverted profits tax and new simplified transfer pricing rules for intra-group low value-adding services . . .

Asia-Pacific

Ireland advises of change to tax treatment of royalty income under treaty with Lithuania

April 15, 2020

Irish Tax and Customs on April 14 announced that the tax treatment of royalty income . . .

Africa

Transfer pricing issues arising from the COVID-19 pandemic

April 14, 2020

Gaurav Jain, an India chartered accountant, and Priya Mani Bhutani, a New Delhi transfer pricing professional, discuss the impact of the COVID-19 crisis on transfer pricing . . .

Asia-Pacific

Japan’s cabinet approves nearly $1 tril. yen (USD 990 billion) coronavirus package which includes some tax relief for business: Kyodo News→

April 14, 2020

Africa

OECD issues welcome guidance on tax treaty issues arising from the COVID‑19 crisis

April 13, 2020

Jian‑Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi of DLA Piper Nederland N.V., Amsterdam, discuss April 3 guidance released by the OECD Secretariat addressing how governments should apply standard tax treaty provisions when multinational group taxpayers or their employees are forced to change their behavior to comply with COVID‑19 travel restrictions and quarantines . . .

Asia-Pacific

Australian Taxation Office assesses Rio Tinto AUD $86.1m (USD 53.6m) for 2010–2016 alleging it sold underpriced aluminum to Singapore marketing hub: Peter Ker / Financial Review→

April 8, 2020

Asia-Pacific

India’s tax response to coronavirus

March 29, 2020

Ritu Shaktawat, a tax partner at Khaitan & Co, Mumbai, discusses tax measures announced by the Indian government on March 24 in response to the coronavirus pandemic . . .

Asia-Pacific

Turkey 7.5 percent digital services enters into force: KPMG→

March 23, 2020

Asia-Pacific

Australia releases synthesized text of tax treaty with Canada as amended by the MLI: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australia increases the number of data validations required before computer system accepts country-by-country reports: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australia updates guidance on interpreting tax treaties: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australian High Court clarifies definition of “associate” in BHP Billiton tax dispute

March 19, 2020

Paul McNab, a Tax Controversy Partner at PwC Sydney, discusses the March 11 decision High Court of Australia in BHP Billiton Limited v Commissioner of Taxation [2020] HCA 5) where the Court addresses the definition of “associate” for tax purposes . . .

Asia-Pacific

New Zealand proposes tax measures in response to COVID-19 outbreak: New Zealand Inland Revenue→

March 18, 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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