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 . . .

Americas

Switzerland rejects Biden’s tax haven claim: swissinfo.ch→

May 3, 2021

Americas

Bermuda leaders chafe at Biden’s tax haven label: Scott Neill / The Royal Gazette→

May 3, 2021

Europe

Ireland amends R&D tax credit guidance to address rental costs

May 3, 2021

An updated version of Irish Revenue’s tax guidance on the research and development (R&D) tax credit, released April 28, adds a section on rent as a qualifying expenditure for R&D activities, among a few other revisions.

Denmark

Denmark Supreme Court rules in Tetra Pak transfer pricing case

April 29, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Supreme Court’s April 26 ruling in a landmark transfer pricing case involving a Danish company Tetra Pak that produced and sold plants for manufacturing ice cream . . .

Europe

Switzerland fears impact of minimum corporate tax rate: Matthew Allen / Swissinfo.ch→

April 28, 2021

Europe

Ireland updates dividend withholding tax guidance to reflect Finance Act 2020 changes: Irish Revenue→

April 28, 2021

Europe

Hungary says global minimum tax would violate sovereignty, refuses to consent: Budapest Times→

April 28, 2021

Americas

French and German finance ministers voice support for US proposal on global minimum tax: Reuters→

April 28, 2021

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 . . .

Europe

EU preferential regimes and Code of Conduct Group: state of play

April 28, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses several developments in April regarding the EU Code of Conduct Group’s effort to rein in tax avoidance . . .

Europe

Spanish guidance clarifies transfer pricing arm’s length range

April 28, 2021

Mario Ortega and Íñigo García, J&A Garrigues, S.L.P., discuss Spain’s February 24 transfer pricing guidance on arm’s length price . . .

Europe

EU’s digital levy proposal to run parallel to OECD talks, Commission official confirms

April 23, 2021

The EU’s proposed digital levy would be in addition to any agreement on taxing large digital companies that arises from OECD talks this year, but the levy will be modest, according to Benjamin Angel, the European Commission’s Director of Direct Tax Policy and acting Director of Indirect Tax Policy. Speaking . . .

Americas

Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says

April 22, 2021

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

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 . . .

Americas

Google UK paid just £50 million (69.14 million USD) in corporate tax last year, despite posting £1.8 billion (2.49 billion USD) of revenues: Chris Newlands / inews→

April 22, 2021

Europe

Poland clarifies its unique definition of “controlled transaction” for transfer pricing purposes

April 22, 2021

Dr. Monika Laskowska, Center of Tax Analyses and Studies, discusses Poland’s early April launch of a public consultation on new transfer pricing guidance defining controlled transactions . . .

Europe

Ireland positions itself as counterpoint to US in debate over global minimum tax

April 21, 2021

Irish Finance Minister Paschal Donohoe today confirmed that Ireland would resist the push for a global minimum tax to the extent that it would infringe on the country’s 12.5 percent corporate tax rate . . .

Belgium

ECJ to rule on whether DAC 6 tax reporting obligation infringes rights

April 21, 2021

A Belgian court has requested a preliminary ruling from the European Court of Justice with respect to whether certain fundamental EU rights are infringed by a provision of DAC 6, which requires mandatory automatic exchange of information in the field of taxation in

Europe

UK tables amendments to hybrid rules

April 20, 2021

The UK government, on April 15, tabled for the Committee of the Whole House amendments to Finance Bill 2021 relating to the corporate tax rules on hybrids and other mismatches . . .

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 . . .

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 . . .

Europe

OECD names new chair of international tax policy body

April 19, 2021

The OECD announced on April 16 that it appointed Fabrizia Lapecorella as the new head of the Committee on Fiscal Affairs starting on January 1, 2022. . .

Africa

Switzerland, Luxembourg do not appear on tax blacklists while island nations do, creating the perception of racial bias, professors say: Steven A. Dean & Attiya Waris / SSRN→

April 19, 2021

Denmark

Danish Ministry of Taxation admits defeat in important transfer pricing case

April 14, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Ministry of Taxation’s March 25 announcement that it was withdrawing its challenge in a 2018 transfer pricing dispute . . .

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

April 14, 2021

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

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 . . .

Europe

Ireland reevaluating tax treaty policy

April 13, 2021

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Americas

Countries should suspend their DSTs now to show they are serious about reaching global agreement on international tax, ranking member says: US Senate Finance Committee→

April 13, 2021

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. . .

Europe

Spanish finance minister says Spain favors global minimum corporate tax, presents committee with broad tax reforms to bolster revenue: Explica.co→

April 12, 2021

Americas

Cyprus divided on Yellen’s minimum corporate tax: Andrew Rosenbaum / CyprusMail→

April 9, 2021

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 . . .

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 . . .

Europe

G20 ministers renew call for consensus over MNE taxation

April 7, 2021

G20 finance ministers and central bank governors on April 7 renewed their call on for agreement on new tax rules for multinational groups. . .

Europe

Luxembourg tax guidance addresses new interest limitation rule

April 6, 2021

Sophie Richard and Adnand Sulejmani, Arendt & Medernach S.A., discuss Luxembourg guidance on the application of a new interest limitation rule, implemented in a new Article 168bis of the income tax law. . .

Europe

Peru tax authority addresses appropriate method for intra-group services under prior law

April 5, 2021

Carlos Vargas Alencastre of TPC Group, Peru, discusses the Peruvian tax administration’s March 18 guidance clarifying the transfer pricing rules applicable to intragroup services. . .

Europe

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

April 1, 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.
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