Asia-Pacific

Africa

Feedback sought on UN model tax treaty provision clarifying taxation of software payments

February 17, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has released a discussion draft and . . .

Africa

Analysis of MNE data in 34 countries shows that thin capitalization rules, by raising the cost of capital, can significantly affect real investment: International Monetary Fund→

February 17, 2021

Africa

UN model treaty draft article 12B allows developing countries to use more straightforward domestic rules to tax the digital economy, WBG staff writes: World Bank Group→

February 17, 2021

Asia-Pacific

EU Code of Conduct Group’s taxation work program released

February 17, 2021

Francesca Amaddeo, a Lecturer-Researcher, at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the Council of the European Union’s February 9 release of the Code of Conduct Group’s new work plan under the Portuguese Presidency . . .

Africa

OECD publishes assessment of cross-border tax dispute resolution in 13 more countries

February 17, 2021

The OECD on February 1 published assessments of the cross-border tax dispute resolution processes in Aruba, Bahrain . . .

Asia-Pacific

EU expected to again delay Turkey’s tax blacklisting, grant more time for compliance with tax information exchange standard: WION→

February 16, 2021

Asia-Pacific

Taiwan amends transfer pricing guidance for intangible transactions

February 16, 2021

Yuanchang, Toby, SU, General Manager, Fu Ten TP Consulting, Taiwan, discusses the final version of Taiwan transfer pricing regulations, released last year . . .

Africa

Stakeholders weigh-in on BEPS Action 14 standards for cross-border tax dispute resolution

February 10, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, discusses an OECD consultation meeting, held February 1, addressing OECD Secretariat proposals with respect to a 2020 review of BEPS Action 14, concerning cross-border tax dispute resolution . . .

Asia-Pacific

Qatar’s new transfer pricing documentation rules

February 10, 2021

Rubeena Dina, Partner at Global Tax Services, UAE and Director at GTS Africa – Mauritius discusses Qatar’s new transfer pricing regulations . . .

Asia-Pacific

Maldives provides English translation of country-by-country reporting regulations: Maldives Inland Revenue Authority→

February 10, 2021

Asia-Pacific

India files suit in Singapore High Court challenging Vodafone arbitration award: ET Telecom→

February 8, 2021

Asia-Pacific

Japan, Switzerland agree to amend tax treaty

February 8, 2021

The government of Japan and the Swiss Federal Council have agreed in . . .

Asia-Pacific

India’s Budget – Implications for the international business community

February 3, 2021

Mukesh Butani and Seema Kejriwal, Partners at BMR Legal, provide a detailed look at the tax implications for the international business community of India’s financial year 2021-22 budget, which includes controversial changes to India’s equalisation levy . . .

Asia-Pacific

Australia says top international MNE compliance risks are profit shifting, related party debt, service hubs, inbound supply chain pricing, PE avoidance, non-arm’s length intangibles arrangements, outbound PE, foreign disposal of property: Australian Taxation Office→

February 3, 2021

Asia-Pacific

Australia confirms that compliance resources will not be used to determine existence of PE in some instances where employees are present due to COVID-19: Australian Taxation Office→

February 2, 2021

Asia-Pacific

Tax ruling addresses whether use of a Singapore investment company’s foreign-sourced dividend income from a related foreign investment company to offset a non-trade related intercompany debt triggers remittance rules: Inland Revenue Service of Singapore→

February 2, 2021

Asia-Pacific

Israeli tax circular addresses intercompany recharges from stock-based compensation

February 2, 2021

Jacky Houlie of JH & Co. Law Office and Shlomo Hubscher, JH Consulting Ltd., Tel Aviv-Yafo, discuss a recently issued tax circular released by the Israeli tax authorities . . .

Africa

First Look: OECD consultation focuses on improving cross-border tax dispute resolution

February 1, 2021

The OECD today hosted a consultation meeting on a planned review of minimum standards, agreed to by OECD and G20 countries in 2015, that aim to improve cross-border tax dispute resolution for multinational . . .

Asia-Pacific

First Look: India’s Budget – A step towards clarity for foreign investor taxation

February 1, 2021

Mukesh Butani and Seema Kejriwal, of BMR Legal in Delhi, take a first look at the Indian government’s budget proposals for 2021–22, released today, focusing on several important proposals that affect international taxation . . .

Asia-Pacific

Hong Kong laws granting profits tax concessions for insurance-related business and setting March 19 the law’s effective date were gazetted, government notes: Hong Kong government→

January 28, 2021

Americas

COVID-19 and tax treaties: the updated OECD guidance

January 27, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader at GTS (Global Tax Services) UAE, discusses the OECD’s updated guidance on COVID-19 and tax issues, issued January 21 . . .

Asia-Pacific

Cairn Energy threatens to seize Indian government assets overseas to enforce 1.2 billion tax arbitration award: Aditi Shah & Aftab Ahmed / Reuters→

January 26, 2021

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

January 25, 2021

Asia-Pacific

Australian guidance addresses how investors holding hybrid securities on capital account determine market value when there is a buy-back or redemption: Australian Taxation Office→

January 22, 2021

Asia-Pacific

China should consider new tax on tech companies, securities regulation official and former vice finance minister say: Cheng Siwei, YU Hairong, Zhang Erchi, and Denise Jia / Nikkei Asia→

January 20, 2021

Asia-Pacific

Vietnam’s transfer pricing regulations create new challenges

January 20, 2021

Tu Ha, Transfer Pricing Director at Duff & Phelps, Vietnam, discusses new Vietnam transfer pricing regulations, effective from December 20, 2020, that replace all former transfer pricing regulations . . .

Africa

Transfer pricing and the cumulative advertising effects on sales

January 20, 2021

Dr. Ednaldo Silva, founder and managing director of RoyaltyStat, Bethesda, Md., discusses the effect of advertising on enterprise-level sales, arguing that marketing intangible producing activities such as advertising expenses cannot coexist with the legal concept of limited function distributor or retailer . . .

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

January 19, 2021

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Americas

Day 2 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Asia-Pacific

Final Australia targeted integrity rule addresses hybrid mismatches: Australian Taxation Office→

January 14, 2021

Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

January 13, 2021

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

January 13, 2021

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Bahrain

Bahrain clarifies VAT place of supply for telecommunication services: National Bureau for Revenue→

January 12, 2021

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Asia-Pacific

Singapore ruling concludes that corporation and three foreign shareholders are not related parties for transfer pricing purposes: Inland Revenue Authority of Singapore→

January 4, 2021

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.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
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