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Accounting
India announces rules for book profits tax relief related to APAs, secondary adjustments
Ashish Mehta and Sanket Shah, Khaitan & Co., discuss the Indian tax administration’s August 10 release of new rules for computing relief related to the tax on book profits in cases where there was an increase in book profits of a particular financial year on account of an advance pricing agreement (APA) or . . .
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 . . .
Africa
Togo becomes latest country to endorse global tax reforms
The West African nation of Togo became the 140th country to join the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) and the 134th Inclusive Framework member to endorse the two-pillar international tax reform statement released earlier this summer, according to an August 31 . . .
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Amgen transfer pricing dispute – is this Medtronic redux?
New York City Economist Dr. J. Harold McClure analyzes the situation surrounding the IRS’s large transfer pricing adjustments for 2010–2015 involving the intercompany pricing between Amgen’s US parent and its Puerto Rican manufacturing affiliate, with issues seeming to mirror those in Medtronic’s . . .
Americas
US Senate unveils international tax reform draft legislation
Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify key provisions of the Republicans’ 2017 tax law, including the global intangible low-taxed income (GILTI) provision, foreign-derived intangible income (FDII), and . . .
Featured News
Global minimum tax’s ‘GloBE’ maze – more than meets the eye!
Noopur Trivedi and Jitesh Golani, international tax researchers, analyze a hypothetical case study evaluating the effect that the intricate rules under the global anti-base erosion (GloBE) proposal in the July 1 OECD/G20 Inclusive Framework statement can have when implemented in a typical multinational . . .
Americas
Europe
Europe
Ukraine clarifies application of transfer pricing rules to transactions with US transparent entities
Yuri Nikolaychuk, Rödl & Partner, discusses the Ukraine state tax service’s July 26 ruling concerning the tax implications of transactions between a Ukrainian taxpayer and a US limited liability company based in Texas, confirming that such transactions can be subject both to the transfer pricing rules . . .
Asia-Pacific
Switzerland confirms 5% withholding tax rate for dividends paid to India, expects reciprocity
Bijal Ajinkya and Raghav Kumar Bajaj, Khaitan & Co, discuss the Swiss tax authority’s August 13 confirmation that dividends received by an Indian resident from a Swiss company will be subject only to a 5% withholding tax rate in Switzerland, but if India does not reciprocate, the Swiss reserve the right to . . .
Americas
Europe
Germany adopts substantial transfer pricing and anti-treaty shopping rule changes
Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .
Americas
Japan releases study group report on international taxation in the digital economy
Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .
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US bill proposing tax on corporate book income could undermine R&D incentives
A bill announced by US Senator Elizabeth Warren (D-Mass.) on August 9 would impose a tax on the income that large corporations report to their shareholders with an aim to prevent those corporations from using “loopholes” – including tax incentives, like the research and development (R&D) tax credit . . .
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