Asia-Pacific

Greece, Australia start tax treaty negotiations: Papadopoulos / Greek City Times→

February 25, 2022

Asia-Pacific

India refunds US $1.1 billion to UK-based Capricorn Energy (formerly Cairn) to settle tax dispute: BusinessLine→

February 25, 2022

Asia-Pacific

R&D in New Zealand: fresh thinking for an innovation culture: Clowney / CrossBorder Solutions→

February 23, 2022

Asia-Pacific

Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25: Yuen / Marketing-Interactive.com→

February 23, 2022

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

February 22, 2022

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

Asia-Pacific

Singapore considers `top-up’ tax to raise MNE group tax rate to 15%: Kit / Channel News Asia→

February 22, 2022

Asia-Pacific

Iran, Finland sign tax treaty: Tasnim News Agency→

February 14, 2022

Africa

Lesotho, Thailand, and Vietnam sign multilateral convention to implement tax treaty-related measures to prevent BEPS: OECD→

February 9, 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.

Asia-Pacific

India’s budget looks to tax cryptocurrencies, extending India’s tax base

February 7, 2022

Mukesh Butani and Seema Kejriwal, BMR Legal Advocates, discuss India’s budget announced on February 1, which carries key tax amendments affecting multinationals doing business in India.

Africa

UAE announces 9% corporate income tax rate, sets tone on regional corporate tax competition

January 31, 2022

Mourad Chatar and Sarah Bahous, Value Square, discuss the United Arab Emirates’ January 31 announcement that it will implement a federal corporate tax regime at a standard nine percent rate, which will apply to relevant businesses from . . .

Asia-Pacific

Sri Lanka to sign new tax treaties with India, Czech Republic, Turkey: Daily Mirror Online→

January 26, 2022

Asia-Pacific

Taiwan highlights changes in new tax treaty protocol with UK

January 18, 2022

Taiwan’s Ministry of Finance on January 18 explained the changes in the new amending protocol to the UK-Taiwan tax treaty, which took effect on January 1 after entering into force on . . .

Asia-Pacific

Malaysia clarifies rules on tax treatment of R&D expenditures

January 14, 2022

The Inland Revenue Board of Malaysia on December 29 published an updated public ruling explaining the rules relating to qualifying research and development (R&D) expenditures for tax incentive deductions; businesses resident in Malaysia that undertake R&D activity may be able to . . .

Asia-Pacific

Australian Taxation Office plans review of advance pricing arrangement program

January 13, 2022

The Australian Taxation Office announced on January 12 that in 2022 it is conducting a review of its advance pricing arrangement (APA) program, focusing on whether the program is assuring transfer pricing risk in the most efficient manner, as well as . . .

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

South Korea to extend R&D tax incentives to technologies related to carbon neutrality, including carbon capture and renewable energy, as well as for rare earth elements facing supply shortages: Yonhap / The Korea Herald→

January 6, 2022

Asia-Pacific

Singapore-Jordan tax treaty enters into force

December 30, 2021

The tax treaty signed by the governments of Jordan and Singapore on July 14 entered into force on December 30 following the necessary ratifications and exchange of diplomatic notes; as a result, the treaty provisions will take effect on . . .

Asia-Pacific

Australian Taxation Office clarifies eligible expenses for R&D tax incentive

December 28, 2021

The Australian Taxation Office on December 23 updated guidance on expenses that may be claimed in connection with research and development (R&D) tax incentives through a ruling on the “at risk” rule and a determination on deductions subsidized by . . .

Armenia

Singapore-Armenia tax treaty enters into force

December 28, 2021

The tax treaty signed between the governments of Armenia and Singapore in July 2019 entered into force on December 23 and will be effective . . .

Asia-Pacific

Taiwan tax agency states that foreign businesses’ fixed places of business in Taiwan that sell services to domestic business entities must issue uniform invoices and file and pay business taxes: R.O.C. Ministry of Finance→

December 21, 2021

Asia-Pacific

Cyprus and Jordan signed tax treaty on December 17 that is based on OECD and UN models and incorporates base erosion and profit shifting (BEPS) minimum standards: Cyprus Ministry of Finance→

December 21, 2021

Americas

ATO prevails in Singapore Telecom Australia intercompany financing litigation

December 20, 2021

New York City Economist Dr. J. Harold McClure analyzes Australia’s Federal Court of Appeals ruling on December 17 in favor of the Australian Tax Office in Singapore Telecom Australia Investments Pty Ltd v. Commissioner of Taxation – a transfer pricing case involving intercompany interest payments in . . .

Asia-Pacific

Australian Taxation Office addresses imported hybrid mismatch rule

December 17, 2021

The Australian Taxation Office describes how it assesses tax compliance risk in connection with imported hybrid mismatch rules in a practical compliance guideline issued December 16; the imported hybrid mismatch rules disallow . . .

Asia-Pacific

OECD review of tax ruling exchange standard finds 36 countries could improve

December 14, 2021

Out of 131 countries the OECD reviewed in a 2020 peer review report released on December 14, 95 received no flags for improvement with respect to implementing the OECD minimum standard on exchange of information on tax rulings; however, 36 countries fell short, including . . .

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

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Asia-Pacific

Australian corporate tax compliance improves under agency efforts, ATO claims

December 10, 2021

The Australian Taxation Office states that its latest annual corporate tax transparency report, published December 10, demonstrates that voluntary tax compliance by large corporations is improving; the percentage of large corporations with a “high assurance” rating has increased from just . . .

Asia-Pacific

Azerbaijan amends tax laws relating to CFCs, tax havens, transfer pricing

December 10, 2021

Leyla Safarova, BM Morrison Partners, discusses Azerbaijan’s significant tax code changes, which will become effective on January 1, 2022, including new controlled foreign corporation (CFC) rules and transfer pricing amendments, as well as measures focused on . . .

Asia-Pacific

Israeli transfer pricing case addresses reclassification of trademark transaction, arm’s-length R&D pricing

December 8, 2021

Assaf Hasson, Assaf Hasson & Co., discusses the Israeli Jerusalem District Court’s recent ruling in favor of the Israel Tax Authority in a transfer pricing case, Sephira & Offek Ltd. and Israel Daniel Amram, involving the reclassification of a trademark transaction between . . .

Asia-Pacific

Taiwan signs tax treaty with South Korea, seeks trade agreements with India and Australia: Lin Chia-nan / Taipei Times→

December 2, 2021

Americas

Brazil-Singapore tax treaty enters into force

December 1, 2021

The tax treaty between Singapore and Brazil, signed in May 2018, entered into force on December 1 and will become effective in January 2022 . . .

Americas

US-Turkey competent authority agreement on exchange of country-by-country reports signed on November 24: US Internal Revenue Service→

December 1, 2021

Americas

India and US agree on transition from India’s ‘equalization levy’ digital tax

November 29, 2021

The US and India have reached a compromise on a transition from India’s “equalization levy” digital services tax towards the terms of the October 8 multilateral agreement on new international taxing rules, according to a November 24 . . .

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

November 23, 2021

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Asia-Pacific

Turkey and US agree on phase-out of digital tax

November 23, 2021

The US Treasury announced on November 22 that it has reached an agreement with the Turkish government on Turkey’s transition from its digital services tax to the new taxing rules under the . . .

Asia-Pacific

Turkey’s new law amends taxation system: change is the only constant

November 22, 2021

Oytun Canyas and Bengisu İncikli, CETINKAYA, discuss a new Turkish law that took effect October 26 and includes numerous amendments to the country’s corporate income tax, tax procedure, VAT, stamp tax, and special consumption tax, among other . . .

Asia-Pacific

Australian Taxation Office delays year-end country-by-country reporting deadline

November 19, 2021

Companies facing a December 31 due date for country-by-country reporting obligations will now have until February 4, 2022, to file the reports, according to a November 18 announcement from the Australian Taxation Office, which said it is granting the extra time due to both the . . .

Asia-Pacific

Indian court extends tax exemption of Abu Dhabi Investment Authority to its Jersey trust

November 19, 2021

Ritu Shaktawat and Milind Hasrajani, Khaitan & Co, discuss the October 28 landmark decision by the High Court of Bombay holding that income from debt securities earned by a Jersey trust settled by the Abu Dhabi Investment Authority (ADIA), and of which ADIA is the sole beneficiary, is exempt . . .

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

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