Asia-Pacific

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Asia-Pacific

China to increase extra tax deduction for R&D expenses of manufacturing firms: State Council→

March 26, 2021

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

Asia-Pacific

New Zealand parliament passes tax bill

March 24, 2021

The New Zealand government today announced that parliament has passed a tax bill that includes measures allowing businesses to claim greater deductions for feasibility expenditures . . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Asia-Pacific

Singapore adopts BEPS-compliant IP tax incentives

March 24, 2021

Edmund Leow SC of Dentons Rodyk & Davidson LLP, Singapore, discusses Singapore regulations on its new concessionary income tax rules for intellectual property, which came into effect on January 22. . .

Asia-Pacific

India appeals Cairn Energy USD 1.4 billion arbitration award: The Economic Times→

March 23, 2021

Asia-Pacific

Mongolia’s first transfer pricing assessment – what could be the issues?

March 23, 2021

Dr. J. Harold McClure, New York economist, discusses the issues surrounding Mongolia’s first transfer pricing assessment. . .

Asia-Pacific

India’s lower house passes Finance Bill, 2021: Hindustantimes→

March 23, 2021

Asia-Pacific

Georgia amends transfer pricing rules for APAs, reduces thresholds

March 23, 2021

Gela Barshovi of TPsolution, Tbilisi, Georgia, discusses March 2 Georgia Ministry of Finance guidance amending the transfer pricing rules concerning the unilateral advance pricing agreement procedure . . .

Asia-Pacific

Bahrain introduces country-by-country reporting requirements

March 23, 2021

Abdulrahman Bucheeri and Raman Ohri of Keypoint Solutions, Manama, discuss Bahrain ministerial guidance introducing country-by-country reporting requirements, released on February 4 . . .

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Asia-Pacific

Mongolia issues first transfer pricing assessment

March 18, 2021

The Mongolian government has issued its first transfer pricing tax assessment, hitting a mining company with a tax bill of approximately USD 228 million and a denial of USD 1.5 billion in carried forward . . .

Asia-Pacific

Australia and Belgium enter into a memorandum of understanding on procedure for arbitration of tax disputes: Australian Taxation Office→

March 18, 2021

Americas

Mathias Cormann appointed OECD Secretary General

March 17, 2021

The OECD council on March 15 named former Australian finance minister Mathias Cormann as its next leader beginning in June. He will become the first secretary-general from. . .

Asia-Pacific

Japanese ministry considers reducing tax burden on Japanese-based tech companies’ overseas earnings: The Mainichi→

March 17, 2021

Asia-Pacific

Transfer pricing for Indian software distribution affiliates

March 17, 2021

New York City economist, Dr. J. Harold McClure, notes that Indian tax authorities may take a closer look at transfer pricing following their loss in a landmark decision involving the taxation of foreign-based software providers . . .

Africa

EU to implement digital levy regardless of OECD-led effort

March 16, 2021

The EU Commission will continue to press ahead with its proposal for an EU digital levy to fund EU operations even if a global international tax . . .

Asia-Pacific

Indonesia to cut taxes for hybrid vehicles: Cindy Silviana, Gayatri Suroyo / Reuters→

March 15, 2021

Asia-Pacific

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

March 15, 2021

Asia-Pacific

India will levy a 40% customs tax on imports of solar modules from April next year to cut dependence on foreign supplies and boost domestic manufacturing of the equipment: Energy Infra Post→

March 10, 2021

Asia-Pacific

UK’s Cairn Energy considers ways to monetize arbitration award it won against India in six-year USD 1.7 billion tax dispute: Business Today→

March 10, 2021

Asia-Pacific

India Supreme Court settles the debate – software sale is not taxable as royalty

March 10, 2021

Ritu Shaktawat and Krutika Chitre, Khaitan & Co, Mumbai, discuss the Supreme Court of India’s new landmark ruling putting to rest a long-standing contentious issue surrounding the characterization of income in the hands of non-resident software manufacturers . . .

Asia-Pacific

Japanese ministry to assemble panel of experts to analyze taxation of digital economy: Japan Ministry of Economy, Trade, and Industry (In Japanese)→

March 3, 2021

Asia-Pacific

First Look: India Supreme Court settles long-running dispute over taxation of software payments

March 2, 2021

India’s Supreme Court today ruled that software payments made by Indian end-users or distributors and resellers to overseas . . .

Asia-Pacific

Australia assesses Rio Tinto AUD 406.5 million (USD 316.5 million) tax plus interest from denial of interest deduction for borrowings to pay intragroup dividend: Businesswire→

March 2, 2021

Asia-Pacific

Japan considers new carbon tax on emissions: Jiji Press→

March 1, 2021

Asia-Pacific

Taiwan to impose new taxes on ecommerce

February 26, 2021

Offshore e-commerce suppliers that sell cross-border electronic services to individuals in the Republic of China (Taiwan) and have annual sales . . .

Asia-Pacific

Malaysia publishes tax guide for foreign digital services providers: Royal Malaysian Customs Department→

February 24, 2021

Asia-Pacific

Hong Kong 2021–22 budget includes one-off reductions in profits tax, salaries tax, and tax under personal assessment: Inland Revenue Department→

February 24, 2021

Africa

Latest updates to EU list of non-cooperative jurisdictions

February 24, 2021

Francesca Amaddeo, a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the February 22 update to the EU’s list of non-cooperative jurisdictions for tax purposes . . .

Asia-Pacific

Thailand requires transfer pricing disclosures to be filed online

February 23, 2021

Paul Ashburn and Rohit Sharma of HLB Advisory (Thailand) Ltd. discuss new Thailand transfer pricing guidance making it mandatory for companies to submit their transfer pricing disclosure forms online . . .

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Africa

Countries agree to new rules for private tax ruling transparency

February 22, 2021

An OECD-led coalition of 139 countries working together on cross-border tax issues known as the “Inclusive Framework on BEPS” has agreed to a new method for assessing whether countries meet global minimum standards for private tax ruling . . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Africa

Proposed UN model treaty article on automated digital services is simpler than OECD/G20 Inclusive Framework proposal and preserves taxing rights of developing countries, IMF subcommittee says: International Monetary Fund→

February 19, 2021

Croatia

Croatia, Malaysia finalize multilateral tax treaty

February 19, 2021

Croatia and Malaysia have deposited their instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Asia-Pacific

Japan-Spain tax treaty to enter into force in May

February 19, 2021

Japan and Spain recently completed the necessary steps . . .

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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