Featured News

Stefano Mariani & Bernie Ng, Deacons, discuss Hong Kong’s gazetting of the Inland Revenue Bill 2021 on 19 March, seeking to expand and clarify the profits tax deductions for foreign taxes . . .

Americas

UN Committee of Experts approves new digital tax article for model treaty

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 . . .

Asia-Pacific

China guidance addresses new tariff and tax incentives for integrated circuit, software industries

Grace Lin, Head of Tax, Cuatrecasas, Shanghai, discusses the Chinese government’s issuance in March of two notices clarifying tariff and tax incentives for the circuit and software industries . . .

Americas

Canada’s 2021 budget includes proposals on digital taxes, profit shifting, interest deductibility

Canada’s Budget 2021, presented by Finance Minister Chrystia Freeland on April 19, proposes several significant tax measures affecting multinational enterprises . . .

Digital Economy

Digital platforms should assist tax compliance efforts, OECD says

The digital platforms that have fueled the growth of the sharing and gig economies have a role to play in value-added tax (VAT) and goods and services tax (GST) compliance and administration, the OECD said . . .

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. . .

Denmark

Danish Ministry of Taxation admits defeat in important transfer pricing case

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

Avery Dennison wins Chile transfer pricing dispute over intercompany loans, distributor margin

Dr. J. Harold McClure, New York City, discusses the multinational manufacturer Avery Dennison Corporation’s March 31 win in its transfer pricing dispute with the Chilean tax authority. . .

Americas

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

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

NGO proposal revises minimum tax to overcome OECD approach’s shortcomings

The proponents of a new minimum effective tax rate proposal for multinational corporations say their proposal would modify the OECD’s proposed global anti-base erosion tax (GloBE) . . .

Americas

US support for R&D has stalled relative to France, UK, others

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 . . .

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

April 13, 2021

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

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. . .

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 . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Americas

Biden fleshes out international tax plan, Senate Democrats offer their take

A US Treasury Department report released on April 7 expands on the corporate tax plan announced by the Biden Administration last week . . .

Americas

Ireland may not agree to global minimum tax, minister says

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

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

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. . .

Asia-Pacific

China enhances R&D super deduction for manufacturing, extends multiple tax breaks for doing business in China

April 6, 2021

Hengka (Henry) JI, Zhong Lun Law Firm, discusses the March 15 release by China’s Ministry of Finance and State Administration of Taxation of “Announcement No. 6 of 2021 Concerning the Extension of Several Preferential Tax Policies”. . .

Antigua and Barbuda

Countries continue to permit tax treaty shopping despite BEPS promises

April 6, 2021

Most countries are not fulfilling their commitment to amend their tax treaties to meet global standards aimed at preventing tax avoidance through tax treaty shopping, an April 1 OECD report shows. . .

Americas

US Treasury Secretary Yellen calls for G20 agreement on global minimum tax

April 5, 2021

US Secretary of the Treasury Janet Yellen said on April 5 that she is working to get buy-in from G20 nations on a global minimum corporate tax . . .

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. . .

Asia-Pacific

China simplifies unilateral advance pricing arrangement procedures for some taxpayers

April 1, 2021

Agnes Lo, Lingnan University, and Raymond Wong, City University of Hong Kong, discuss China’s State Taxation Administration’s March 19 guidance simplifying unilateral advance pricing arrangement procedures for some taxpayers. . .

Americas

Biden’s corporate tax plan would increase rates, upend international provisions

President Biden’s corporate tax plan released on March 31 would raise the US corporate tax rate to 28%, increase the global minimum tax and calculate it on a country-by-country basis. . .

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Proposed OECD model tax treaty updates cover transfer pricing for interest payments, corresponding adjustments

The OECD on March 29 proposed changes to its model tax convention commentary that would alter language regarding the arm’s length treatment of interest payments between associated enterprises located in different countries and clarify a state’s obligation . . .

Europe

Poland issues guidance on controversial rules requiring additional disclosures for transactions involving tax havens

Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics, discusses new Polish guidance on disclosures required by taxpayers that conduct business with tax haven entities. . .

Americas

US IRS shortened completion time for advance pricing agreements in 2020 but backlog remains

The US IRS cut the median time to complete advance pricing agreements (APAs) down to 32.7 months in 2020, a drop of over six months from last year, its best completion time in five years, IRS statistics published on March 30 reveal. . .

Europe

Ireland updates and expands tax guidance on anti-hybrid rules

Irish Revenue updated the anti-hybrid provisions in its tax manual on March 29 to reflect amendments made by Finance Act 2020 with respect to how the anti-hybrid rules apply to a worldwide system of taxation. . .

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance