Asia-Pacific

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Asia-Pacific

South Korean tax reform proposal includes enhanced R&D incentives

July 27, 2021

A tax reform bill introduced by the South Korean government on July 26 includes research and development (R&D) measures aimed at promoting . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Asia-Pacific

Singapore–Indonesia updated tax treaty enters into force

July 23, 2021

An updated tax treaty between Singapore and Indonesia entered into force on July 23, replacing . . .

Asia-Pacific

Oman suspends local filing transfer pricing reporting requirement

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses Oman’s July 7 announcement suspending the country-by-country local filing requirement until . . .

Asia-Pacific

United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses the United Arab Emirates’ July 1 release of mutual agreement procedure (MAP) guidance for resolving tax and transfer pricing disputes through. . .

Asia-Pacific

Philippines and Brunei signed tax treaty on July 16: Philippines Department of Finance→

July 19, 2021

Asia-Pacific

Japan and Switzerland sign tax treaty protocol

July 16, 2021

Japan and Switzerland on July 16 signed an amending protocol to the tax treaty between the countries that would revise the treatment of taxes on investment income, among . . .

Asia-Pacific

Hong Kong will implement international consensus on BEPS 2.0 while striving to maintain tax advantages in terms of simplicity, certainty, and fairness: Hong Kong Inland Revenue Department→

July 14, 2021

Asia-Pacific

Australia consults on patent box R&D tax incentive

July 13, 2021

The Australian government on July 5 launched a consultation on the design of its planned patent box regime announced in the . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Asia-Pacific

Jordan implements formal transfer pricing rules

July 12, 2021

Nour Ali, DNV, discusses Jordan’s June 7 adoption of official transfer pricing rules for the first time through regulation No. 40 of 2021, implementing . . .

Asia-Pacific

Australian draft tax ruling clarifies when software gives rise to royalties

July 8, 2021

Draft guidance issued by the Australian Taxation Office on June 25 describes the circumstances under which receipts from the licensing and distribution of software will . . .

Accounting

Australian Accounting Standards Board clarifies deferred tax recognition rules

July 8, 2021

The Australian Accounting Standards Board (AASB) on July 2 amended its guidance on accounting for deferred tax with respect to transactions that give rise to . . .

Asia-Pacific

UK-based Cairn Energy garners court order in France to seize Indian government property valued at more than EUR 20 million in enforcement of international arbitration award: Tribune India→

July 8, 2021

Asia-Pacific

Thai Board of Investment offers enhanced R&D tax incentives

July 7, 2021

The Thai Board of Investment on June 30 approved several measures to encourage further investment in research and development (R&D), including . . .

Asia-Pacific

Taiwan Ministry of Finance reminds businesses claiming foreign tax credits to ensure foreign tax liability should not have been reduced or exempted under applicable tax treaty: R.O.C. Ministry of Finance→

July 7, 2021

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Asia-Pacific

Pakistan 2021-22 budget’s tax and economic measures: a friend or foe

July 6, 2021

Muhammad Khurram Shabbir, Ph.D. student, NUML Islamabad, discusses Pakistan’s budget, released on June 11, which cuts the capital gains tax, removes a series of withholding taxes . . .

Asia-Pacific

Qatar extends transfer pricing filing deadline to 30 September

July 6, 2021

Rubeena Dina, Global Tax Services, discusses Qatar’s June 17 announcement extending the deadline to file master and local files for the fiscal year ending December 31, 2020 . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Thank you to our MNE Tax founder and community as we grow our platform

July 1, 2021

We are launching an exciting new chapter at MNE Tax, expanding our content and community of expert contributors in collaboration with our new parent CrossBorder Solutions. We would not have gotten to this point without . . .

Americas

US Treasury Secretary stresses importance of India’s support for ‘robust global minimum tax’ in call with Indian Finance Minister: U.S. Treasury→

June 29, 2021

Asia-Pacific

Australian R&D tax incentive draft ruling clarifies ‘at risk’ rule

June 29, 2021

A draft tax ruling issued by the Australian Taxation Office on June 25 explains the circumstances in which a company’s research and development (R&D) tax offset could be . . .

Philippines

Philippines to be removed from OECD harmful tax regimes list in January 2022 following enactment of legislation eliminating preferential tax rates for regional operating headquarters: Philippines Department of Finance→

June 28, 2021

Asia-Pacific

Taiwan transfer pricing decree on bilateral APAs takes sensible approach

June 28, 2021

New York City Economist Dr. J. Harold McClure discusses Taiwan’s June 24 decree on negotiating and implementing bilateral APAs, stating that it shows a sensible and flexible approach . . .

Americas

Japan–Uruguay tax treaty enters into force July 23

June 24, 2021

The tax treaty signed by the governments of Japan and Uruguay on September 13, 2019, will enter into force. . .

MNE Tax joins CrossBorder Solutions!

June 23, 2021

MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Georgia

Japan–Georgia tax treaty signed January 29 will enter into force on July 23 following June 23 exchange of diplomatic notes: Japan Ministry of Finance→

June 23, 2021

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

China

China may not have much to lose under global corporate minimum tax and could hinge its support on US’s willingness to lift tariffs on Chinese goods: Frank Tang / South China Morning Post→

June 21, 2021

Asia-Pacific

China increases tax relief for science and technology companies

June 21, 2021

Hengka (Henry) JI and Jiannan Zhu, Zhong Lun Law Firm, discuss Chinese government announcements issued March 16 – April 15 implementing tax policies promoting scientific and technological innovation and the development . . .

Americas

US Senate approves bill with R&D funding for semiconductor industry

June 17, 2021

The US Senate passed with bipartisan support on June 8 a bill that would authorize new funding for research and development (R&D) to boost . . .

Asia-Pacific

Singapore updates tax guidance for advertising industry: Inland Revenue of Singapore→

June 16, 2021

Asia-Pacific

India has little to gain under G7 tax agreement

June 14, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses how, for developing countries like India, the agreement that the G7 finance ministers reached on June 5 may bring little new tax revenue while imposing . . .

Germany

Indonesian, Mexican, South African finance ministers join German, US counterparts in op-ed endorsing global minimum tax of at least 15%: Arturo Herrera Gutiérrez, Sri Mulyani Indrawati, Tito Mboweni, Olaf Scholz and Janet L. Yellen / Washington Post→

June 10, 2021

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

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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