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Europe

Europe

Finland proposal would remove VAT exemption for small imported online purchases imported outside the EU: Ministry of Finance→

February 26, 2021

 

Africa

US drops demand that “pillar one” global tax compromise be a safe harbor

February 26, 2021

The US will no longer require that any coordinated “Pillar One” update to the international tax and transfer pricing rules be drafted as a “safe harbor.”  The announcement . . .

Europe

Luxembourg’s 2021 budget law

February 26, 2021

Jan Neugebauer and Henner Heßlau, Arendt & Medernach S.A., Luxembourg discuss Luxembourg’s 2021 budget law . . .

Europe

EU court rejects Swedish rules limiting deductions for cross-border interest payments

February 24, 2021

Emiliha Ferrão, a transfer pricing specialist at Thorning Koponen Consulting in Stockholm, Sweden, discusses the implications of a European Court of Justice ruling, issued January 20, on Swedish tax rules that limit deductions for some cross-border interest payments . . .

Europe

ActionAid, Christian Aid Ireland, Oxfam call on Ireland to drop opposition to public country-by-country reporting: Naomi O’Leary / The Irish Times→

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 . . .

Europe

Spain to scrutinize taxpayers’ transfer pricing positions in 2021

February 24, 2021

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss the Spanish government’s priorities for tax enforcement, set out in a January 19 announcement . . .

Featured News

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 . . .

Europe

In a call with EU Commission’s Valdis Dombrovskis, US treasury secretary commits to re-engage in OECD-led global tax discussion: US Department of the Treasury→

February 23, 2021

     

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 . . .

Europe

EU Commission launches public consultation on VAT rules for financial and insurance services: EU Commission→

February 18, 2021

     

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
Europe

Netherlands adds new minimum substance requirements to conditional withholding tax anti-abuse rule

February 17, 2021

Roderik Bouwman and Rhys Bane, DLA Piper, Amsterdam, discuss the Netherlands government’s latest regulations clarifying the new conditional withholding tax on interest and royalty payments, which became effective on January 1. . . .

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 . . .

Digital Economy

Is the EU (unintentionally) undermining ongoing OECD work on digital taxation?

February 17, 2021

Oliver Treidler, TP&C GmbH, discusses the January 14 European Commission inception impact assessment and request for public feedback on the design of an EU digital levy . . .

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
Europe

UK asks for public input on tax and regulatory changes needed to improve its investment funds regime: HM Treasury→

February 16, 2021
Europe

Ireland updates tax guidance on controlled foreign company rules to reflect Finance Act 2020 changes: Irish Tax and Customs→

February 16, 2021

→

Europe

EU Code of Conduct Group (Business Taxation) publishes work program for Portuguese Presidency: European Council→

February 10, 2021

   

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 . . .

Europe

Portugal increases taxes on the acquisition and ownership of real estate assets

February 10, 2021

Diogo Ortigão Ramos and João Pedro Russo, Cuatrecasas, Portugal discuss tax changes introduced by the Portuguese State Budget for 2021 which are effective January 1 . . .

Digital Economy

UK exploring options for new tax on online sales: Sky News→

February 10, 2021
Europe

Ireland updates tax guidance on company residence to reflect the end of transition period provided in the Finance Act 2014: Irish Tax and Customs→

February 10, 2021
Europe

EU digital tax proposals are unwarranted and flawed, tax policy group argues: Daniel Bunn / Tax Foundation→

February 9, 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 . . .

Europe

Switzerland aims to make tax system more competitive

February 8, 2021

Switzerland’s Federal Department of Finance is developing new tax rules designed to improve Switzerland’s attractiveness as a business . .

Europe

Poland APA statistics reveal alarming trends

February 3, 2021

Dr. Monika Laskowska of the Center of Tax Analyses and Studies, Warsaw School of Economics, discusses trends in Poland’s advance pricing agreement program, as revealed by recent statistics published by Poland’s tax authority . . .

Americas

EU Commission’s grounds for appeal in Apple State aid tax case published: European Court of Justice→

February 3, 2021

       

Europe

Guernsey advises financial intuitions of new country-by-country reporting schema and reporting requirements: States of Guernsey Revenue Service→

February 2, 2021
Europe

Guernsey informs reporting entities of country-by-country reporting schema change and reporting requirements: States of Guernsey Revenue Service→

February 2, 2021
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 . . .

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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
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  • 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
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  • The Evolution of Transfer Pricing in Saudi Arabia
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  • The Functional Analysis—What You Need to Know
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  • 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
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • 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
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

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