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Asia-Pacific

Asia-Pacific

India intercompany financing: debt versus equity and the pricing of intercompany loans

September 15, 2021

New York City Economist Dr. J. Harold McClure discusses the Mumbai Income Tax Appellate Tribunal’s August 20 ruling against the Indian tax authority in Bennett Coleman & Co Ltd (As successor to Times Infotainment Media Limited) v. Deputy Commissioner of Income Tax, and analyzes the two questions . . .

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

India-US bilateral advance pricing agreements and tax benefits for US multinationals

September 15, 2021

E. Miller Williams, Jr. and Richard L. Slowinski, Alston & Bird, discuss the growing demand for bilateral advance pricing agreements (APAs) between India and the US due to the high potential for adjustments and the risk of . . .

Asia-Pacific

UK–Taiwan tax treaty protocol signed

September 13, 2021

On September 13, the UK government published an amending protocol to the tax treaty between the UK and Taiwan, which would amend the . . .

Asia-Pacific

Australian Taxation Office challenges in court availability of legal professional privilege for tax advice offered by Big 4 accounting firms: Paul McNab / Linkedin→

September 8, 2021
Americas

US R&D tax incentives will be among least generous unless Congress acts, study finds

September 8, 2021

The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a September 7 study from . . .

Americas

European banks’ tax haven use persists but varies widely, study finds

September 7, 2021

Large European banks report an average of 20% of their profits in tax havens, but some report more than half of their profits in such jurisdictions while others report none, according to a September 6 report from the EU Tax Observatory . . .

Asia-Pacific

Sri Lanka updates transfer pricing rules for country-by-country reporting

September 3, 2021

Ramaly Rahuman, Numerix (Pvt) Ltd, discusses Sri Lanka’s introduction of a new regulation on July 20, effective from fiscal year 2020–21, outlining requirements for country-by-country reporting, the master file, and local file, relying on . . .

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 . . .

Australia

Dutch intercompany financing rulings and the transfer pricing of intercompany loans

September 2, 2021

New York City Economist Dr. J. Harold McClure analyzes a July 16 Dutch Supreme Court decision on intercompany financing and discusses how the terms of the intercompany loan show that the tax authority also could have challenged the intercompany interest rate as . . .

Asia-Pacific

Singapore tax agency rules on taxpayers’ hybrid instruments

September 1, 2021

The Inland Revenue Authority of Singapore on September 1 published two income tax advance rulings (10/2021, 11/2021) concluding that certain securities are debt securities under the . . .

Accounting

India announces rules for book profits tax relief related to APAs, secondary adjustments

September 1, 2021

Ashish Mehta and Sanket Shah, Khaitan & Co., discuss the Indian tax administration’s August 10 release of new rules for computing relief related to the tax on book profits in cases where there was an increase in book profits of a particular financial year on account of an advance pricing agreement (APA) or . . .

Asia-Pacific

Taiwan tax agency advises on trading gains from foreign exchange options

August 31, 2021

An August 31 statement from Taiwan’s Ministry of Finance states that companies with trading gains from trading foreign exchange options must include those gains in taxable income, explaining that companies . . .

Asia-Pacific

Vietnam’s new transfer pricing APA regulations – some hurdles but still promising

August 30, 2021

Tu Ha, Duff & Phelps, discusses the new detailed guidance from Vietnam’s Ministry of Finance on the advance pricing agreement (APA) program, which came into effect on August 3, introducing both some new challenges and . . .

Asia-Pacific

South Korean tax revision bill includes incentives to spur economy

August 27, 2021

Ross Harman and Jeongwoo Park, Lee & Ko, discuss the July 26 Korean government’s proposed 2021 tax revision bill, including expanded tax reductions for start-ups, extended job creation tax credits, and enhanced research and development (R&D) tax credits, among . . .

Asia-Pacific

Australian bill introduced to require tax reporting by digital platforms

August 26, 2021

Legislation introduced in Australia’s House of Representatives on August 25 would require digital platform operators to report to the Australian Taxation Office certain information on . . .

Africa

Most favored nation clauses in tax treaties between high- and lower-income countries operate to the disadvantage of the latter, resulting in significant tax base erosion: Deepak Kapoor / ICTD→

August 26, 2021
Accounting

Dozen countries deemed ‘highly inflationary’ for accounting standard purposes

August 23, 2021

The Center for Audit Quality, in a report published August 20, flagged 12 economies as potentially highly inflationary for purposes of US GAAP Accounting Standards Codification (ASC) 830, Foreign currency matters.

Asia-Pacific

Russia looking into revising tax treaties with Switzerland, Hong Kong, and Singapore, according to government official, following three other recent treaty revisions and renunciation of Dutch treaty: Fahad Shabbir / UrduPoint News→

August 23, 2021
Asia-Pacific

Switzerland confirms 5% withholding tax rate for dividends paid to India, expects reciprocity

August 23, 2021

Bijal Ajinkya and Raghav Kumar Bajaj, Khaitan & Co, discuss the Swiss tax authority’s August 13 confirmation that dividends received by an Indian resident from a Swiss company will be subject only to a 5% withholding tax rate in Switzerland, but if India does not reciprocate, the Swiss reserve the right to . . .

Americas

Extending Australian tax office’s example of transfer pricing implications from demise of LIBOR

August 20, 2021

New York City Economist Dr. Harold McClure analyzes an example from the Australian Tax Office’s August 12 discussion paper on how to address the transfer pricing implications from the demise of London interbank rates, scheduled to . . .

Africa

Cape Verde and Singapore signed tax treaty on August 17: Cabo Verde Inforpress→

August 19, 2021
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 . . .

Asia-Pacific

Australia consults on tax and transfer pricing effects of inter-bank offered rate reforms

August 18, 2021

The Australian Taxation Office describes, in an August 12 discussion paper, common tax consequences and transfer pricing considerations resulting from changes made to financial arrangements in response to reforms to inter-bank offered rates (IBORs), seeking input on . . .

Asia-Pacific

 China simplifies application procedure for unilateral advance pricing arrangements

August 17, 2021

Grace Lin, Cuatrecasas, discusses China’s new simplified procedure for applying for a unilateral advance pricing arrangement (APA), which was announced in Notice No. 24/2021 on July 30 and will be implemented from . . .

Asia-Pacific

Singapore–Serbia tax treaty enters into force

August 16, 2021

The double tax treaty signed earlier this year between the governments of Singapore and Serbia entered into force on August 16 and will generally have effect beginning in . . .

Asia-Pacific

Gulf Cooperation Council countries and businesses prepare for global minimum tax

August 16, 2021

Raman Ohri, Keypoint, discusses the dilemma that the July 1 inclusive framework agreement on a global minimum tax created for Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates . . .

Americas

Singapore guidance on intercompany financing: two illustrations

August 13, 2021

New York City Economist Dr. J. Harold McClure analyzes two examples the Inland Revenue Authority of Singapore (IRAS) provided on August 10 in the sixth edition of its e-tax transfer pricing guidance, extending its coverage of . . .

Asia-Pacific

India withdraws retrospective amendment to tax indirect transfers, big relief for many multinationals

August 13, 2021

Anjul Mathur and Amit Sharma, RSM India, discuss India’s August 4 introduction of a new regulation to withdraw a 2012 amendment, with retrospective effect from 1961, under which the indirect transfer of assets located in India and owned by non-residents was taxed . . .

Asia-Pacific

Taiwan amends tax treaty rules on residency, permanent establishment, treaty abuse

August 12, 2021

On August 12, Taiwan’s Ministry of Finance promulgated amendments to the regulations governing the application of double tax treaties to update the decade-old rules for developments in international tax trends and conventions, improve administrability, and . . .

Asia-Pacific

Singapore joins multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting: OECD→

August 11, 2021
Africa

Maldives, Papua New Guinea, and Rwanda join multilateral treaty for international tax cooperation and exchange of information: OECD→

August 11, 2021
Asia-Pacific

Singapore updates transfer pricing guide to address cost-sharing, financial transactions

August 10, 2021

The Inland Revenue Authority of Singapore on August 10 published the sixth edition of its e-tax guide on transfer pricing, adding a new chapter on cost contribution arrangements, expanding guidance on . . .

Accounting

IASB proposes amendment for insurers, European accounting group responds

August 9, 2021

The International Accounting Standards Board (IASB) on July 28 proposed a limited change to the transition requirements in International Financial Reporting Standards (IFRS) 17, Insurance Contracts, intending to address . . .

Asia-Pacific

Hong Kong tax agency advises on tax and transfer pricing effects of Covid-19

August 9, 2021

The Hong Kong Inland Revenue Department on July 29 clarified its approach to the disruptions caused by Covid-19 with respect to various tax issues, including issues related to tax residence, permanent establishment . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

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 . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Asia-Pacific

India’s first year of ‘faceless’ tax assessments runs into legal issues

August 3, 2021

Suranjali Tandon from the National Institute of Public Finance and Policy, New Delhi, analyzes several court decisions issued in June and July that highlight implementation issues with India’s new “faceless” – i.e., digital – tax assessment scheme, which was intended . . .

Posts navigation

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What’s Next

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Add Your Event
RECENT COMMENTS
  • 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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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • 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

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
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Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.