Europe

Norway proposes important changes to rules on tax-free cross-border reorganizations

November 2, 2021

Sander Pettersen, CMS Kluge Advokatfirma AS, discusses the Norwegian Ministry of Finance’s September 3 release of a proposal to simplify cross-border mergers, demergers and share exchanges to facilitate . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Europe

UK to update diverted profits tax for MAP relief, relieving provisions

October 29, 2021

The UK government will adopt legislative amendments to include the diverted profits tax among the taxes for which relief may be granted under the mutual agreement procedure (MAP) of an applicable tax treaty, according to an October 27 policy paper released in connection with . . .

Accounting

Canadian accounting board calls for more disclosures on tax and accounting differences

October 29, 2021

The Canadian Accounting Standards Board recommended to the International Accounting Standards Board (IASB) in a letter published October 26 that enhanced disclosure requirements are needed with respect to the relationship between tax expenses and accounting profits, responding to an . . .

Americas

White House’s hopes of an international tax revenue windfall may be overblown

October 29, 2021

Alex M. Parker, Capitol Counsel LLC, discusses how, without the political support for raising tax rates, Democrats are looking to an overhaul of the international tax system to help pay for the USD 1.75 trillion spending package; but some recent estimates say . . .

Europe

UK will amend R&D tax reliefs, increase bank corporate tax rate

October 28, 2021

The UK government announced plans to reform tax incentives for research and development (R&D) as well as increase the corporate tax rate for banks as part of the 2021 autumn budget . . .

Europe

Italy introduces new patent box regime

October 27, 2021

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss Italy’s October 21 repeal and replacement of the former patent box regime, which, from 2021 onwards, shift it from a profit-based incentive to an extra deduction for certain R&D costs incurred by . . .

Europe

EU Commission seeks to ease withholding tax mechanism on cross-border investments

October 26, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the EU Commision’s public consultation launched September 28 on an initiative to address impediments to cross-border investment posed by the burdensome nature of withholding tax mechanisms, which according to . . .

Europe

Ireland tax guide reviews mandatory disclosure regime

October 25, 2021

Irish Revenue on October 22 incorporated into its tax manual guidelines on the mandatory disclosure regime, setting out guidance notes regarding the required reporting of certain transactions that are . . .

Europe

Netherlands issues policy decree clarifying hybrid mismatch tax measures

October 25, 2021

Jian-Cheng Ku, Rhys Bane, and Mehdi el Manouzi, DLA Piper Nederland N.V., discuss the Dutch government’s October 11 decree clarifying hybrid mismatch measures of the EU Anti-Tax Avoidance Directive 2 (ATAD 2), based on the first experiences with the . . .

Africa

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

October 25, 2021

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities’ introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and Africa . . .

Digital Economy

Irish Finance Bill 2021 adopts transfer pricing, international tax changes

October 22, 2021

The Finance Bill 2021 released by the Irish government on October 21 sets out legislative changes related to transfer pricing, anti-tax avoidance measures, planned tax treaty ratifications, and various . . .

Accounting

European digital services taxes to stay for now, with offsetting credits, countries agree

October 21, 2021

Under an October 21 agreement between the United States and Austria, France, Italy, Spain, and the UK, the European countries can keep their existing digital services taxes in place pending implementation of Pillar 1 of the OECD global tax deal; however, multinational groups . . .

Europe

Germany updates tax dispute resolution and mutual agreement procedures

October 21, 2021

Timo Turek, Ypsilon International GmbH, discusses Germany’s updated guidance from August 27 on international dispute resolution, replacing the existing guidance from 2018, which, for the first time . . .

Customs

European Commission work programme 2022 includes tax projects

October 21, 2021

The European Commission will work to ensure “swift and consistent” implementation within the EU of the two-pillar global tax agreement to show “EU’s leadership in global tax fairness,” according to its work programme 2022 released October 19, including a new . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Estonia

Estonia’s joining global tax deal may mean some companies will look elsewhere, but there will be no mass exodus, and Estonian companies could have been worse off outside deal, Finance Ministry predicts: Baltic Times→

October 19, 2021

Europe

France amends rules regarding withholding tax calculation for dividends

October 19, 2021

Nathalie Valluis, French tax lawyer, discusses Article 7 of the French Finance Bill for 2022, released September 22, which, If adopted as it stands, will allow non-resident legal entities to re-calculate the withholding tax applicable to dividends from French sources on a . . .

Europe

Italy-France tax treaty’s interaction with parent-subsidiary EU directive

October 19, 2021

Michele Targa, Gatti Pavesi Bianchi Ludovici, discusses the Italian Supreme Court’s September 15 decision on the concurrent application of the Italy-France tax treaty and an EU directive to a dividend distribution by a French-resident subsidiary to its Italian-resident . . .

Africa

Country-by-country reporting adopted in more than 100 jurisdictions, OECD reports

October 18, 2021

More than 100 jurisdictions have in place a domestic legal framework for requiring country-by-country reporting by large multinational enterprises, according to an OECD report released October 18, noting that additional jurisdictions have . . .

Europe

EU Advocate General opinion addresses Finnish taxation of non-Finnish investment funds

October 15, 2021

Ville Alahuhta, Bird & Bird Attorneys Ltd., discusses the EU Advocate General’s October 6 publication of an opinion on the Finnish tax treatment of a French investment fund in case C-342/20, addressing the . . .

Accounting

European accounting group’s top priorities: intangibles, sustainability, crypto

October 14, 2021

The European Financial Reporting Advisory Group (EFRAG) on October 11 recommended to the International Accounting Standards Board (IASB) what it considers to be the highest priority projects for . . .

Europe

EU directive will implement OECD tax deal ‘as is’

October 13, 2021

The European Commission “will try” to deliver in December a directive to implement the OECD tax deal within the EU and that directive “will implement the agreement as is,” according to October 12 comments by Benjamin Angel, Director of the European Commission DG TAXUD, who . . .

Austria

Austria updates transfer pricing guidelines

October 13, 2021

Iris Burgstaller, TPA Austria and Baker Tilly, discusses the Austrian Ministry of Finance’s October 7 publication of the final version of the revised Austrian transfer pricing guidelines, replacing the 2010 guidelines to incorporate OECD developments, particularly the . . .

Accounting

Ireland 2022 budget’s tax changes include 15% corporate rate, new incentives

October 12, 2021

The Irish government’s Budget 2022, announced October 12, includes an increase in the corporate tax rate to 15% in line with last week’s OECD tax agreement, expanded relief for start-up companies, a new tax credit for . . .

Africa

European Parliament approves proposal to step up fight against harmful tax practices

October 12, 2021

Vasiliki Koukoulioti, Ph.D. researcher at Queen Mary University of London, discusses the European Parliament’s October 7 adoption of a draft resolution calling for an in-depth reform of European policy to combat harmful tax practices by toughening . . .

Europe

CJEU to review German transfer pricing obligation: do national tax rules affect EU freedoms?

October 11, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses Germany’s July 15 request that the European Court of Justice review German transfer pricing documentation requirements and associated sanctions in the case C-431/21, X GmbH & Co. v Finanzamt Bremen, following . . .

Bulgaria

EU advocate general opinion addresses withholding tax on unpaid interest

October 11, 2021

Stoycho Dulevski, Kolev, Angelov & Miteva Law Firm, discusses the September 30 EU Advocate General’s opinion regarding the assessment of withholding tax on unpaid interest in Case С-257/20 Vivacom Telecom Bulgaria, focusing on the . . .

Europe

UK R&D tax credit claims continue rapid growth

October 8, 2021

The total number of UK research and development (R&D) tax credit claims for the year ending March 2020 was up 16% from the previous year, and has doubled in the past five years, according to government statistics released September 30.

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Europe

EU will not take UK to court over Gibraltar tax-related state aid

October 7, 2021

The European Commission on October 6 announced that it has decided to repeal its decision to refer the UK to the European Court of Justice over Gibraltar’s failure to . . .

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Asia-Pacific

Hong Kong plans tax changes to get off EU’s ‘gray list’

October 6, 2021

The government of Hong Kong on October 5 responded to the EU’s inclusion of Hong Kong in its updated “gray list” of jurisdictions that do not yet comply with certain international tax standards, stating that it . . .

Europe

‘Polish Deal’ tax reform passes lower house

October 6, 2021

The “Polish Deal” corporate tax bill on October 4 moved to the Senate after the Polish parliament’s lower house (Sejm) approved the bill, which includes changes to transfer pricing regulations, a new . . .

Africa

EU removes three jurisdictions from tax ‘black list’

October 5, 2021

The European Council on October 5 approved the removal of Anguilla, Dominica, and Seychelles from the EU’s list of non-cooperative jurisdictions for tax purposes, the so-called “black list,” and moving . . .

Europe

Italy draft guidance clarifies transfer pricing documentation requirements

October 5, 2021

Giuliana Polacco, Annarita De Carne, Francesco Drago and Camilla Cominelli, Studio Legale Bird & Bird, discuss the Italian Revenue Agency’s September 20 publication of the draft of a long-awaited circular letter on transfer pricing, focused on the documentation necessary to verify the correct application . . .

Americas

Switzerland, Estonia, Ireland seek concessions in global tax deal

October 4, 2021

OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive Framework’s July statement referring to . . .

Europe

Greek bill would cut corporate income tax rate by 30% for three years for mergers between small- and medium-sized enterprises: Eirini Chysolora / eKathimerini→

October 4, 2021

Accounting

European accounting group comments on IASB draft subsidiary disclosure requirements

October 1, 2021

The European Financial Reporting Advisory Group (EFRAG) on September 30 published draft comments on the International Accounting Standards Board’s (IASB) July 26 exposure draft that would permit eligible subsidiaries to apply International Financial Reporting Standards (IFRS) with reduced disclosure requirements in their . . .

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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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