Asia-Pacific

Americas

India may oppose US proposal to tax only top 100 companies: Dilasha Seth / Business Standard→

May 10, 2021

Asia-Pacific

Singapore rules on tax treatment of hybrid securities

May 5, 2021

The Inland Revenue Authority of Singapore ruled that securities issued by a Singapore-based company constituted “debt securities” under the rules characterizing hybrid instruments in two rulings issued May 3 . . .

Asia-Pacific

Taiwan stipulates filing requirement for foreign businesses selling electronic services

May 4, 2021

Certain foreign businesses earning income from cross-border electronic services sold to individuals in the Republic of China (Taiwan) must file income tax returns for 2020 through the online “eTax Portal” . . .

Asia-Pacific

How prudent is it to conduct transfer pricing risk adjustments for captive cost centres?

May 4, 2021

Smarak Swain, New Delhi, discusses India’s Income Tax Appellate Tribunal’s recent decision in a transfer pricing dispute, GCO Technologies Centre Pvt Ltd, focusing on whether adjustments should have been made to the comparables to reflect the captive service provider’s risk levels. . .

Asia-Pacific

Global minimum tax opponents will not stop agreement, Saint-Amans says

May 4, 2021

Negotiations on a global minimum tax on corporations have the momentum that they need to reach an agreement now that France, Germany, and others have signaled support for recent US proposals. . .

Asia-Pacific

New Singapore transfer pricing guide addresses MNE centralised services

May 4, 2021

Adriana Calderon, Transfer Pricing Solutions Asia Pte Ltd, discusses the Inland Revenue Authority of Singapore’s release on March 19 of transfer pricing guidelines on centralized services . . .
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Europe

Singapore and Serbia sign income tax treaty

May 4, 2021

Singapore and Serbia have signed an income tax treaty, Singapore’s Inland Revenue Authority announced on May 3 . . .

Asia-Pacific

New Zealand enhances R&D tax credit refundability to lessen impact of COVID-19

May 3, 2021

New Zealand’s Inland Revenue has brought forward by one year the application date of broader refundability for the R&D tax credit in a move intended to help businesses retain their R&D capability during the COVID-19 outbreak, the government said . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Americas

US Treasury Secretary Yellen says tax moves needed to help tackle climate change

April 22, 2021

US Secretary of the Treasury Janet L. Yellen spoke on April 21 of the Biden administration’s “whole-of-government approach” to aggressively tackling climate change – including creating a targeted investment tax credit . . .

Asia-Pacific

Maldives publishes advance pricing arrangement regulations

April 22, 2021

Zaina Zahir, CTL Strategies, discusses the Maldives Inland Revenue Authority’s advance pricing arrangement regulations published on March 16 . . .

Asia-Pacific

Netflix Korea reports its 2020 financials: transfer pricing implications

April 21, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Netflix’s new 2020 financial reporting in South Korea . . .

Asia-Pacific

Australian tax guidance clarifies compliance with imported hybrid mismatch rules

April 21, 2021

The Australian Taxation Office issued draft guidance on April 21 regarding its assessment of compliance with the imported hybrid mismatch rules. The guidance is intended to help taxpayers prepare for compliance reviews. The imported hybrid mismatch rules aim to prevent taxpayers from entering

Asia-Pacific

Philippines updates procedures for claiming tax treaty benefits

April 21, 2021

John Regalado & Tanya Beatriz Y. Tan, SyCip Salazar Hernandez & Gatmaitan, discuss the Philippine government’s March 31 memorandum that streamlines the procedures for access to Philippine tax treaty benefits . . .

Hong Kong proposes new rules enhancing deductibility of foreign tax

April 20, 2021

Stefano Mariani & Bernie Ng, Deacons, discuss Hong Kong’s gazetting of the Inland Revenue Bill 2021 on 19 March, seeking to expand and clarify the profits tax deductions for foreign taxes . . .

Americas

UN Committee of Experts approves new digital tax article for model treaty

April 20, 2021

The UN Committee of Experts on International Cooperation in Tax Matters today agreed to the text of a new article and commentary for the UN model tax treaty that would grant . . .

Asia-Pacific

China guidance addresses new tariff and tax incentives for integrated circuit, software industries

April 20, 2021

Grace Lin, Head of Tax, Cuatrecasas, Shanghai, discusses the Chinese government’s issuance in March of two notices clarifying tariff and tax incentives for the circuit and software industries . . .

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Asia-Pacific

Google Korea, Facebook Korea report income for the first time but in questionable sum: Hong Sung-yong & Minu Kim / Pulse→

April 14, 2021

Americas

US confident “vast majority” of developed nations will approve global minimum tax, US deputy treasury secretary says: Thomas Franck / CNBC→

April 14, 2021

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

April 13, 2021

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

Africa

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

April 12, 2021

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Asia-Pacific

Turkey considers raising corporate income tax rate to 25% for 2021, then reducing to 23%: bne IntelIiNews→

April 12, 2021

Americas

India unlikely to agree to global minimum tax: Arup Roychoudhury / Moneycontrol→

April 9, 2021

Asia-Pacific

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

April 9, 2021

Asia-Pacific

Australian court holds R&D tax offset refund was paid by mistake, subject to recovery provision

April 8, 2021

The Federal Court of Australia held on March 19 that a research & development tax offset refund claimed by, and paid to, a taxpayer, but to which the taxpayer was not entitled, is subject to . . .

Africa

US offers new “Pillar One” compromise plan for taxing large multinationals

April 8, 2021

The Biden administration has proposed a new “Pillar One” scheme for taxing multinational groups to a coalition of 139 countries . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Americas

Ireland may not agree to global minimum tax, minister says

April 7, 2021

There may not be agreement among all G20 nations on a global minimum corporate tax, according to Ireland’s Finance Minister and Eurogroup President Paschal Donohoe, who . . .

Africa

UN tax committee releases updated model treaty language on automated digital services

April 7, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters today released its final draft of proposed Article 12B and commentary on income from automated digital . . .

Asia-Pacific

China enhances R&D super deduction for manufacturing, extends multiple tax breaks for doing business in China

April 6, 2021

Hengka (Henry) JI, Zhong Lun Law Firm, discusses the March 15 release by China’s Ministry of Finance and State Administration of Taxation of “Announcement No. 6 of 2021 Concerning the Extension of Several Preferential Tax Policies”. . .

Asia-Pacific

Singapore updates guidance on business foreign exchange gains or losses: Inland Revenue of Singapore→

April 1, 2021

Asia-Pacific

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

April 1, 2021

Asia-Pacific

China simplifies unilateral advance pricing arrangement procedures for some taxpayers

April 1, 2021

Agnes Lo, Lingnan University, and Raymond Wong, City University of Hong Kong, discuss China’s State Taxation Administration’s March 19 guidance simplifying unilateral advance pricing arrangement procedures for some taxpayers. . .

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

March 31, 2021

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Americas

US IRS shortened completion time for advance pricing agreements in 2020 but backlog remains

March 31, 2021

The US IRS cut the median time to complete advance pricing agreements (APAs) down to 32.7 months in 2020, a drop of over six months from last year, its best completion time in five years, IRS statistics published on March 30 reveal. . .

Asia-Pacific

Taiwan advises sellers of digital goods and services to apply for tax registration

March 30, 2021

Individuals who use online platforms or social media software to sell goods or services for profit must apply for tax registration. Taiwan’s National Taxation Bureau of Kaohsiung, Ministry of Finance, said on March 26. . .

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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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