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Asia-Pacific

Singapore updates transfer pricing guide to address cost-sharing, financial transactions

August 10, 2021

The Inland Revenue Authority of Singapore on August 10 published the sixth edition of its e-tax guide on transfer pricing, adding a new chapter on cost contribution arrangements, expanding guidance on . . .

Americas

Brazil’s upcoming tax reform will impact inbound investors

August 10, 2021

Luis Felipe de Campos, Rolim, Viotti, Goulart, Cardoso Advogados, discusses the substitute tax reform bill that Brazil’s Ministry of Economy presented to Congress on June 25, including provisions affecting corporate tax rates, profit distributions, interest . . .

Americas

Colombian tax reform proposes corporate rate increase, tax avoidance measures

August 10, 2021

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian government’s introduction of a tax reform bill on July 20 that includes an increase in the corporate tax rate, new measures to . . .

Asia-Pacific

Hong Kong tax agency advises on tax and transfer pricing effects of Covid-19

August 9, 2021

The Hong Kong Inland Revenue Department on July 29 clarified its approach to the disruptions caused by Covid-19 with respect to various tax issues, including issues related to tax residence, permanent establishment . . .

Americas

Panama Papers: Luxembourg court confirms tax agency’s authority to request information from lawyers

August 6, 2021

Rafael Rivera, Managing Partner and Tax & Legal Partner at BDO Panama, discusses the Luxembourg High Administrative Court’s July 13 decisions – pertaining to the so-called “Panama Papers” cases – that overruled a lower court and held that the tax administration . . .

Europe

Spain tightens international tax transparency rules and introduces concept of ‘non-cooperative jurisdictions’

August 5, 2021

Abigail Blanco Vázquez and Álvaro de la Cueva of J&A Garrigues, S.L.P., discuss Spain’s law published on July 9 to prevent and combat tax fraud (Law 11/2021), triggering changes to various tax concepts and to the general taxation law itself. Provisions in the anti-fraud law affecting corporate income tax and . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Denmark

Denmark proposes easing transfer pricing documentation requirements between related Danish companies

August 4, 2021

Rasmus Christian Johansen, Danish Tax Agency, discusses the Danish Ministry of Taxation’s June 23 proposed draft amendments to the Danish Tax Control Act to relax the transfer pricing documentation requirements for some . . .

Europe

Poland business transfer pricing forum advises on Covid-19 impact

August 3, 2021

Dr. Monika Laskowska at the Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish Ministry of Finance’s July 13 publication for public consultation of recommendations on the impact of Covid-19 on transfer pricing . . .

Asia-Pacific

India’s first year of ‘faceless’ tax assessments runs into legal issues

August 3, 2021

Suranjali Tandon from the National Institute of Public Finance and Policy, New Delhi, analyzes several court decisions issued in June and July that highlight implementation issues with India’s new “faceless” – i.e., digital – tax assessment scheme, which was intended . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Europe

Greece adopts new value-added tax rules on e-commerce

July 29, 2021

Emmanouela Kolovetsiou-Baliafa, KG Law Firm, discusses Greece’s July 18 adoption of new value-added tax (VAT) rules for online crossborder transactions, applying . . .

Americas

Global minimum tax could create confusion with current CFC rules

July 28, 2021

Thomas Locher, Tax Foundation’s Center for Global Tax Policy, discusses how the implementation of a global minimum tax could create confusion with current CFC rules, raising questions about . . .

Europe

Iceland adopts administrative fines for transfer pricing documentation

July 27, 2021

Ólafur Evert Úlfsson, Skatturinn – Iceland Revenue and Customs, discusses the Icelandic parliament’s May 31 passage of new rules that allow Iceland Revenue and Customs to impose administrative fines on taxpayers that fail to fulfill their transfer pricing . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Europe

Germany introduces new administrative principles for transfer pricing

July 23, 2021

Oliver Treidler, TP&C GmbH, discusses Germany’s July 14 release of new administrative principles for transfer pricing that are effective immediately and will constitute a focal point of the German transfer pricing . . .

Europe

UK draft bill would require uncertain tax treatment reporting, amend hybrid rules

July 22, 2021

The UK on July 20 published draft legislation for Finance Bill 2021-22 to create an uncertain tax treatment notification requirement for large businesses and amend the tax rules for hybrids and other mismatches, among . . .

Europe

Germany adopts ATAD rules on exit taxation, CFCs, hybrids

July 22, 2021

Timo Turek, partner at Ypsilon International GmbH, discusses Germany’s June 30 implementation of the Anti-Tax Avoidance Directive (ATAD) into law, affecting exit taxation, controlled foreign corporation (CFC) taxation reform, intra-EU anti-hybrid rules, as well as . . .

Asia-Pacific

Oman suspends local filing transfer pricing reporting requirement

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses Oman’s July 7 announcement suspending the country-by-country local filing requirement until . . .

Asia-Pacific

United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses the United Arab Emirates’ July 1 release of mutual agreement procedure (MAP) guidance for resolving tax and transfer pricing disputes through. . .

Americas

Ireland seeks input on OECD tax proposals’ impact on Irish tax policy

July 20, 2021

The Irish Department of Finance on July 20 opened a consultation on implications for Ireland’s corporate tax policy arising from the two-pillar proposal for overhauling the international tax framework recently . . .

Americas

Chilean guidance addresses enhanced foreign tax credit rules under 2020 tax reform

July 20, 2021

Tomás Kovacevic, Barros y Errázuriz Abogados, discusses the Chilean tax agency’s May 19 clarification of the amended foreign tax credit rules enacted in Chile’s 2020 tax reform through guidance issued . . .

Americas

Brazilian tax reform’s second phase includes corporate, investment proposals

July 20, 2021

Carolina Becman and Kassia Paulo, Gaia Silva Gaede Advogados, discuss the Brazilian government’s June 25 presentation of the second phase of its proposed tax reform, which aims to change the income tax legislation for individuals and legal entities, as well as establish . . .

Americas

Nike’s transfer pricing state aid dispute: the underlying issues

July 19, 2021

New York City Economist Dr. J. Harold McClure analyzes the issues underlying the transfer pricing dispute involving Nike, following the General Court of the European Union’s July 14 ruling declining to annul the European Commission’s state aid investigation regarding . . .

Denmark

Denmark finally implements ATAD amendments to CFC regime

July 19, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish parliament’s June 3 passage of a bill to adopt changes to the controlled foreign corporation (CFC) regime necessary for the implementation of the EU Anti-Tax Avoidance Directive (ATAD) . . .

Americas

Mexico’s outsourcing schemes’ demise and its tax and transfer pricing effects

July 19, 2021

Jesús Aldrin Rojas, Managing Partner at QCG Transfer Pricing Practice, discusses tax and transfer pricing considerations for business groups in Mexico following the country’s reform to various tax and labor laws to prohibit outsourcing of personnel, published in the official gazette on April 23 . . .

Africa

Kenya’s Finance Act 2021 amends tax policy approach to global market

July 19, 2021

Samuel Okumu, Tax Consultant at Rödl & Partner Limited, discusses the Kenyan Finance Act 2021, enacted on June 29, which includes numerous amendments to the Income Tax Act, VAT Act and Tax Procedures Act that focus on taxation of cross-border transactions by . . .

Europe

EU court rejects Nike’s challenge of transfer pricing state aid investigation

July 14, 2021

The General Court of the EU on July 14 dismissed an action by Nike to annul a decision by the European Commission to investigate whether advance pricing agreements (APAs) concluded by the Netherlands with Nike constituted . . .

No global minimum tax holdouts have left negotiations, OECD official notes

July 14, 2021

Speaking virtually at a July 13 Tax Policy Center event, Grace Perez-Navarro, Deputy Director of the OECD’s Centre for Tax Policy and Administration, said the seven countries that have yet to sign onto the statement endorsing the adoption of a global minimum tax have their reasons for holding off, but . . .

Carbon Tax

EU ‘Green Deal’ includes energy tax changes, carbon border adjustment mechanism

July 14, 2021

The European Commission on July 14 adopted its “Green Deal” package of proposals to address climate change through various policy measures, including revisions to the tax system applicable to energy products and a new . . .

New multinational tax allocation rules will ‘overlay’ transfer pricing rules, OECD official says

July 13, 2021

Speaking virtually at a July 13 Tax Policy Center event, Grace Perez-Navarro, Deputy Director of the OECD’s Centre for Tax Policy and Administration, explained that the new transfer pricing allocation rules recently endorsed by 130+ countries partially set aside the arm’s length principle but do not . . .

Europe

Poland proposes changes to transfer pricing regulations

July 13, 2021

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s June 28 launch of taxpayer-friendly amendments to its transfer pricing regulations, including changes to regulations introduced in 2019 that . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Asia-Pacific

Jordan implements formal transfer pricing rules

July 12, 2021

Nour Ali, DNV, discusses Jordan’s June 7 adoption of official transfer pricing rules for the first time through regulation No. 40 of 2021, implementing . . .

Belgium

Belgium proposes tax bill on foreign loss deductions

July 12, 2021

Moïse Gnakouri, Catholic University of Louvain, discusses the Belgian government’s May 27 draft bill that would change the income tax code regarding the conditions for deducting losses realized by . . .

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