Africa
Featured News
Asia-Pacific
The Korean tax authorities’ challenge to Netflix’s transfer pricing
Dr. Harold McClure, a New York City economist, notes the Korean National Tax Service’s August 27 announcement that it is investigating the transfer pricing practices of 21 multinationals, including US technology and media multinational, Netflix, and considers what the tax service’s transfer pricing dispute with Netflix might be. . .
Americas
Americas
Digital Economy
Americas
New Brazil digital services tax law under discussion
Francisco Lisboa Moreira, a Tax Partner at Bocater Advogados, São Paulo, Brazil, and Doris Canen, an International Tax LLM at Kings College/UK, São Paulo, Brazil, write about a Brazil bill, submitted August 18, which proposes to tax large tech companies on gross income derived from digital services provided to Brazilian customers . . .
Europe
Asia-Pacific
Africa
Africa
Americas
Americas
Americas
Asia-Pacific
Asia-Pacific
Asia-Pacific
Americas
Americas
Cyprus
Africa
Asia-Pacific
Asia-Pacific
Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia
Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .
Asia-Pacific
Americas
Public input sought on Brazil, OECD transfer pricing harmonization
Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .
Americas
Asia-Pacific
Asia-Pacific
Featured News
Americas
Brazil proposal requires foreign digital platforms to collect new consumption tax
Francisco Lisboa Moreira, a tax partner at Bocater Advogados, discusses a bill presented by the Brazilian government to Congress on July 21 that would modify the country’s indirect tax laws and make digital platforms responsible for the tax liabilities of non-resident sellers of physical and digital goods . . .
Africa
Asia-Pacific
Hong Kong revises transfer pricing guidance on advance pricing arrangements
Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss the Hong Kong’s Inland Revenue Department’s July 15 revisions to guidance setting out the Hong Kong government’s interpretation and practice relating to advance pricing arrangements . . . .
Asia-Pacific
Australia addresses transfer pricing treatment of Covid-19 support payments
Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP discuss July 15 Australian Taxation Office guidance on the transfer pricing treatment of payments made under Australia’s JobKeeper program, which provides financial support to employers that have been materially affected by the Covid-19 pandemic . . .
Americas
Africa
The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office
Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .
Europe
Africa
Europe
EU Commission tax package includes review of tax law approval process, VAT reform
Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland discusses the EU Commission’s tax package, released July 15; the Commission says it will explore a new mechanism for enacting tax legislation without the approval of all EU states and offers significant amendments to European VAT rules . . .
Asia-Pacific
India widens its digital tax net by enabling tax payments
Jaiman Patel, Partner – Transfer Pricing (Financial Services), at EY India, discusses the Indian government’s July 3 release of an amended tax form to enable payment of India’s new equalisation levy, a clear indication that the government will not heed requests to defer the reporting or payment of this new tax on nonresident e-commerce operators . . .
Europe
