Europe
Europe
Africa
Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal
Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .
Africa
Asia-Pacific
Europe
Poland considers delayed introduction of ‘hidden divided’ non-deductibility concept
Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Finance Ministry’s September 28 announcement that it might postpone until 2023 its plans to introduce a controversial provision that would limit the deductibility of so-called “hidden dividend” payments as part of the “Polish Deal” tax bill that . . .
Accounting
Europe
Europe
Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids
Jian-Cheng Ku, Gabriël van Gelder, and Rhys Bane, DLA Piper Nederland N.V., discuss the Dutch government’s September 21 tax proposals for 2022, including several direct tax measures that would affect multinational enterprises, such as limiting unilateral downward transfer pricing adjustments and . . .
Europe
Americas
OECD’s GloBE rules: Blending in with jurisdictional blending
Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of “jurisdictional blending” for computation of effective tax rate, and consequent top-up tax, is one of the most pivotal . . .
Belgium
Belgian court rules against retroactive application of transfer pricing guidelines
Moïse Gnakouri, Catholic University of Louvain, discusses a June 8 decision from Belgium’s Court of Appeal of Ghent in a transfer pricing dispute between the Belgian tax authorities and a taxpayer in a case involving the application of a concept introduced in OECD transfer pricing guidelines in a tax year prior to . . .
Accounting
Groups urge FASB to prioritize public country-by-country tax reporting
The US Financial Accounting Standards Board should adopt in its standard-setting agenda a requirement for companies to report information in the notes to their financial statements on the disaggregation of country-by-country income tax, according to a September 22 letter signed by 63 organizations that . . .
Denmark
Europe
Estonia
Asia-Pacific
Belgium
Europe
Africa
Europe
Asia-Pacific
India intercompany financing: debt versus equity and the pricing of intercompany loans
New York City Economist Dr. J. Harold McClure discusses the Mumbai Income Tax Appellate Tribunal’s August 20 ruling against the Indian tax authority in Bennett Coleman & Co Ltd (As successor to Times Infotainment Media Limited) v. Deputy Commissioner of Income Tax, and analyzes the two questions . . .
Europe
Europe
Russia
Cyprus
Asia-Pacific
Europe
Europe
Europe
Estonia
Europe
Americas
Europe
Americas
Africa
Americas
Australia
Accounting
US congressman seeks to delay change in R&D expensing rules
In an August 26 letter, Congressman John Larson (D-Conn.) urged House Ways and Means Chairman Richard Neal (D-Mass.) to include in the “chairman’s mark” of the budget reconciliation bill a four-year delay in the upcoming requirement for companies to amortize research and development (R&D) expenditures . . .
Accounting
