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Europe

Accounting

European accounting group seeks input on IASB agenda

May 24, 2021

The European Financial Reporting Advisory Group (EFRAG) on May 20 issued a joint consultation document seeking input on the International Accounting Standard Board’s (IASB) future agenda . . .

Europe

Commission recommends EU states grant up to EUR 3 million carryback of losses to at least 2019 to help businesses that have suffered from COVID-19 pandemic : EU Commission→

May 24, 2021
Europe

Ukraine’s new transfer pricing reporting forms

May 24, 2021

Yuri Nikolaychuk, Associate Partner, Rödl & Partner, Kyiv, discusses recent updates to Ukraine’s required transfer pricing documentation . . .

Americas

The EU Commission’s objections to Amazon’s transfer pricing approach

May 24, 2021

New York City Economist Dr. J. Harold McClure examines why the EU Commission’s objections to Amazon’s transfer pricing approach resulted in Amazon’s win . . .

Accounting

UK Financial Reporting Council notes cash flow statement errors are a recurrent problem

May 21, 2021

The UK’s Financial Reporting Council (FRC) on May 19 published a Thematic Briefing: The audit of cash flow statements, noting the results of the FRC’s constructive engagement findings and the efforts audit firms have taken to shore up the audit of cash flow statements . . .

Americas

US agrees to 15% global minimum tax rate, boosting odds for Pillar 2 agreement

May 21, 2021

The US, which has been leading the push for a global agreement on a minimum corporate tax, has proposed a minimum tax rate of 15% – a concession from the 21% rate that the Biden Administration previously . . .

Accounting

EU financial advisory members to field test IASB proposals

May 21, 2021

The European Financial Reporting Advisory Group (EFRAG) is asking companies to commit to field testing certain International Accounting Standards Board (IASB) proposals over the next few months . . .

Europe

EU Advocate General advises on Portugal’s disparate tax treatment of dividends

May 20, 2021

Advocate General Kokott of the Court of Justice of the European Union (CJEU), in a May 6 opinion, advised the CJEU to rule that EU free movement of capital requirements . . .

Americas

New Zealand will levy digital services tax on locally-derived revenues of Google, Facebook if no OECD accord is reached, Revenue Minister says: Jonathan Milne / newsroom.pro→

May 20, 2021
Europe

Poland plans enhanced R&D tax incentives in economic recovery effort

May 20, 2021

The Polish Ministry of Finance announced on May 5 various tax plans, including enhanced research and development incentives, in connection . . .

Europe

Ireland likely to oppose EU plan for unified tax base: Eoin Burke-Kennedy / The Irish Times→

May 20, 2021
Europe

Italy to introduce 20% R&D credit for work on drugs, including COVID-19 vaccines, if company grants non-exclusive licenses to third-parties: Reuters→

May 20, 2021
Europe

EU report finds states could improve policies on R&D incentives, tax avoidance

May 19, 2021

The European Commission’s Annual Report on Taxation 2021, released May 18, finds that EU member states have made progress in bringing their tax policies in line with EU priorities, but areas for improvement remain . . .

Americas

UK firm Cairn Energy sues Air India to enforce a USD 1.2 billion arbitration award in tax dispute against India: Euan Rocha & Jonathan Stempel / Reuters→

May 19, 2021

   

Europe

The UN transfer pricing manual’s guidance on IP valuation and royalty rates

May 19, 2021

New York City Economist, Dr. J. Harold McClure, discusses the latest edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released April 27, which includes some useful observations on the nature of intangible assets, yet it has a very sparse discussion of the evaluation of intercompany royalty rates . . .

Austria

ECJ rules interest payments due for untimely value-added tax refunds

May 19, 2021

The European Court of Justice ruled on May 12 that refunds resulting from adjustments to the amount of value-added tax that a taxpayer owes must be paid with interest when not paid within a reasonable period of time . . .

Digital Economy

Ambitious EU tax agenda includes new common corporate tax base proposal

May 18, 2021

The European Commission on May 18 announced several proposals that would dramatically alter the taxation of multinational groups, including proposals to allocate MNE profits among EU states using formulary apportionment and require MNEs to publish their effective tax rates . . . .

Europe

EU court’s state aid decision in Amazon tax case published in English

May 18, 2021

The General Court of the European Union on May 17 published the English-language version of its decision holding that the European Commission failed to establish . . .

Europe

Switzerland advances withholding tax reform

May 17, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the Swiss Federal Council’s April 15 proposal to exempt Swiss interest income from federal withholding tax . . .

Europe

Ukraine’s new transfer pricing rules expand taxpayer obligations

May 17, 2021

Ivan Shynkarenko, KM Partners, WTS Global, Kyiv, discusses Ukraine’s recent changes to its tax code affecting the transfer pricing . . .

Accounting

UK’s Financial Reporting Council announces appointments to its advisory panel

May 13, 2021

The UK’s Financial Reporting Council (FRC) on May 4 announced the appointment of 19 members to its advisory panel, established a few months prior . . .

Europe

Luxembourg welcomes EU court’s judgment that Amazon tax treatment did not violate state aid law, will “examine” judgment finding state-aid advantage in ENGIE case: Luxembourg Government→

May 13, 2021
Africa

If US and EU states can convince large emerging economies to adopt GloBE, MNEs will pay double-digit billions more tax, face increased complexity, Professor says: Joachim Englisch / SSRN→

May 13, 2021
Europe

Perrigo in discussions to settle $1.9B Irish tax bill, dispute concerns IP sales taxed as trading income at 12.5% instead of 33%: Seeking Alpha→

May 12, 2021
Europe

The UN transfer pricing manual’s guidance on intercompany interest rates in the extractive sector

May 12, 2021

New York City Economist, Dr. J. Harold McClure, discusses several examples in the United Nations transfer pricing manual’s chapter on the extractives sector that address how to set appropriate intercompany interest rates . . .

Europe

First Look: Luxembourg and Amazon win tax-related state aid dispute, EU prevails in Engie 

May 12, 2021

The General Court of the European Union on May 12 issued a judgment annulling a European Commission . . .

Europe

Proposed rules would allow EU to block acquisitions by foreign companies receiving tax benefits

May 12, 2021

On May 5, the European Commission proposed regulations that would enable it to scrutinize and potentially block acquisitions of EU-based companies by companies that benefit from certain preferential foreign tax treatments . . .

Europe

Finland to remove VAT exemption for imported purchases

May 11, 2021

The Finnish government plans to remove a value-added tax (VAT) exemption for small imported online purchases in July, Finland’s Ministry of Finance announced May 6 . . .

Europe

European Court of Human Rights upholds EUR 1,000 (USD 1,200) fine against ex-PricewaterhouseCoopers employees for providing tax returns to journalists in LuxLeaks scandal: Molly Quell / Courthouse News Service→

May 11, 2021
Asia-Pacific

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

May 11, 2021

Ritu Shaktawat and Rahul Jain, Khaitan & Co., discuss the High Court of Delhi’s April 22 ruling in a landmark judgment concerning the interpretation of the India-Netherlands tax treaty’s most favored nation clause . . . 

Europe

ECJ to this week hear Luxembourg’s appeal of the General Court’s decision in Fiat which approved the Commission’s use of the arm’s length principle to determine if a tax ruling gives rise to State aid: Seán McCárthaigh / Irish Times→

May 11, 2021
Europe

Ireland’s top 10 companies paid more than half of corporate tax last year: Seán McCárthaigh / The Irish Times→

May 10, 2021
Americas

Global deal on MNE tax reform likely by October, Saint-Amans tells the French Senate’s finance committee: Reuters→

May 10, 2021
Europe

Ukraine tax authorities adopt new rules for nonresident registration

May 7, 2021

Iryna Kalnytska, GOLAW, discusses Ukrainian tax guidance concerning foreign (non-resident) companies that must register with Ukrainian tax authorities . . .

Digital Economy

UK supports Biden’s global tax deal proposal, with caveats

May 6, 2021

The UK’s primary interest in international tax talks is addressing digital taxation and the allocation of taxing rights under the OECD’s “Pillar One,” but it is okay with the US’s not-digital-only approach to Pillar One, according to Mike Williams . . .

Americas

Danish High Court rules on beneficial ownership of dividends for tax purposes

May 5, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a highly-anticipated High Court of Eastern Denmark ruling issued May 3 that resolves two tax disputes concerning beneficial ownership . . .

Europe

Finnish court decisions on tax neutral mergers with US companies may have positive implications for shareholders in other EU states

May 5, 2021

Marianna Santamala, Bird & Bird Attorneys Ltd, discusses two recent Finnish Supreme Administrative Court decisions that may have a wider impact on shareholders located in the European Union . . .

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. . .

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
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→
    April 6, 2022

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

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • 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
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • Italian tax authorities accuse Booking.com of VAT fraud by Daniele Majorana | posted on June 30, 2021

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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.