Featured News

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Europe

Italian revenue agency’s new tax assessment guidelines affect multinationals

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss the Italian revenue agency’s May 7 guidelines describing its plans to prevent and fight tax evasion, along with an indication of how it will . . .

Asia-Pacific

Pakistan 2021-22 budget’s tax and economic measures: a friend or foe

Muhammad Khurram Shabbir, Ph.D. student, NUML Islamabad, discusses Pakistan’s budget, released on June 11, which cuts the capital gains tax, removes a series of withholding taxes . . .

Asia-Pacific

Qatar extends transfer pricing filing deadline to 30 September

Rubeena Dina, Global Tax Services, discusses Qatar’s June 17 announcement extending the deadline to file master and local files for the fiscal year ending December 31, 2020 . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Thank you to our MNE Tax founder and community as we grow our platform

July 1, 2021

We are launching an exciting new chapter at MNE Tax, expanding our content and community of expert contributors in collaboration with our new parent CrossBorder Solutions. We would not have gotten to this point without . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Europe

Italian tax authorities accuse Booking.com of VAT fraud

June 30, 2021

Daniele Majorana, MICCINESI Tax, discusses the Italian finance police’s June 10 announcement of an investigation into whether online travel agency Booking.com evaded payment of around EUR 153 million (USD 182 million) in value-added tax (VAT) . . .

Europe

Dutch report on international tax and transfer pricing rulings reflects new ruling practice

June 29, 2021

Clive Jie-A-Joen and Monique van Herksen, Simmons & Simmons LLP, analyze the June 15 Dutch Revenue Service’s 2020 annual report on international tax rulings, focusing particularly on the advance pricing agreements that . . .

Europe

Spain amends MAP rules for tax and transfer pricing disputes

June 29, 2021

Mario Ortega Calle and Íñigo García Fernández, J&A Garrigues, S.L.P., discuss Spain’s June 8 approval of Royal Decree 399/2021, improving its mutual agreement procedure (MAP) for resolving double taxation . . .

Asia-Pacific

Australian R&D tax incentive draft ruling clarifies ‘at risk’ rule

June 29, 2021

A draft tax ruling issued by the Australian Taxation Office on June 25 explains the circumstances in which a company’s research and development (R&D) tax offset could be . . .

Asia-Pacific

Taiwan transfer pricing decree on bilateral APAs takes sensible approach

June 28, 2021

New York City Economist Dr. J. Harold McClure discusses Taiwan’s June 24 decree on negotiating and implementing bilateral APAs, stating that it shows a sensible and flexible approach . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Europe

Russian tax authorities clarify application of domestic general anti-avoidance rules

June 23, 2021

Alexey Ryabov, JTI Russia, discusses Russian tax guidance issued on March 11 establishing criteria for applying the general anti-avoidance rule under Article 54.1 of the tax code aimed at . . .

Africa

G20 draft communique reportedly endorses global minimum tax

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Digital Economy

OECD develops exchange framework for digital platform tax reporting

The OECD sets out in a June 22 report a multilateral competent authority agreement for the automatic exchange of information relating to income derived by . . .

Americas

Argentina establishes simplified transfer pricing reporting regime

Hernán Ubertazzi, 3D Asesores, discusses the Argentine tax agency’s June 18 guidance simplifying the transfer pricing reporting regime to alleviate burdens on taxpayers that are considered . . .

Accounting

Finnish court accepts US GAAP as basis for transfer pricing in landmark ruling

Heikki Vesikansa, Jenni Parviainen, and Stefan Stellato, Hannes Snellman Attorneys Ltd., discuss a key June 2 Finnish Supreme Administrative Court ruling (SAC 2021:73), confirming the acceptability of a foreign . . .

Asia-Pacific

China increases tax relief for science and technology companies

June 21, 2021

Hengka (Henry) JI and Jiannan Zhu, Zhong Lun Law Firm, discuss Chinese government announcements issued March 16 – April 15 implementing tax policies promoting scientific and technological innovation and the development . . .

Americas

Biden will craft R&D tax incentives with congressional input

June 17, 2021

US Treasury Secretary Janet Yellen said during a June 16 Senate Finance hearing that strengthening tax incentives for research and development (R&D) . . .

Europe

Finland court rejects tax authority’s transfer pricing approach to intercompany interest rates

June 17, 2021

New York City Economist Dr. Harold McClure discusses a May 21 Finnish Supreme Administrative Court decision which rejected the Finnish tax authority’s attempt to increase the intercompany interest rates charged by a Finnish financing affiliate to its Russian operating affiliate . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Europe

Romania implements new rules for establishing tax residence

June 16, 2021

Felix Tapai and Oana Săvulescu, MPR Partners, discuss a May 17 Romanian questionnaire affecting foreign legal entities seeking to establish tax residence . . .

Europe

Finnish tax administration publishes statements addressing transfer pricing guidelines and effect of COVID-19 on permanent establishment rules

June 16, 2021

Ville Alahuhta, Bird & Bird Attorneys Ltd, discusses the Finnish tax administration’s April 19 and 21 guidance clarifying its position on the retroactive effect of updates to the OECD transfer pricing guidelines and the effects of COVID-19 . . .

Europe

EU will propose minimum tax legislation if G20 reaches deal, commissioner says

June 14, 2021

The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 . . .

Asia-Pacific

India has little to gain under G7 tax agreement

June 14, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses how, for developing countries like India, the agreement that the G7 finance ministers reached on June 5 may bring little new tax revenue while imposing . . .

Americas

Argentina introduces progressive corporate income tax

June 14, 2021

Rodrigo Marabi, LM Abogados, discusses the Argentine Congress’ approval on June 2 of a corporate income tax reform replacing the 30% fixed rate with a progressive tax rate . . .

Europe

Ukraine implements mutual agreement procedure for resolving tax disputes

June 10, 2021

Viktoriia Bublichenko, GOLAW, discusses the Ukraine finance ministry’s March 26 decree establishing the detailed order of conduct of the mutual agreement procedure (MAP) for resolving international tax disputes . . .

Europe

Iceland, Liechtenstein, Norway tax-related state aid investigations close

June 9, 2021

Investigations into the tax-ruling practices of Iceland, Liechtenstein, and Norway have found no evidence of the countries’ tax rulings being used in violation of state aid rules, according to a June 4 . . .

Americas

Biden tax plan sets aside money for R&D incentives, but details lacking

June 9, 2021

The Biden Administration proposes to enhance incentives for research and development (R&D) using revenue repurposed from the proposed repeal of the deduction for foreign-derived intangible income (FDII), according to . . .

Americas

Yellen says global minimum tax is necessary to preserve sovereignty

June 9, 2021

Harmful international tax competition, unchecked by any minimum tax, has eroded governments’ sovereignty to collect corporate taxes, stripping governments of funds necessary to address urgent fiscal priorities, according to a June 4 letter from US Treasury Secretary Yellen . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Americas

Coca-Cola says tax court erred in transfer pricing dispute, seeks reconsideration

The Coca-Cola Company on June 2 asked the US Tax Court to reconsider and set aside its November 2020 transfer pricing decision, in which it determined that Coca-Cola’s US income should be increased by . . .

Austria

How will the European Commission define shell companies to stop tax avoidance?

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Americas

Perú tax authority considerations about the use of multi-year data in determining arm’s length transfer pricing

Zaida Limongi, TP Consulting Perú, discusses the Peruvian tax administration’s April 15 transfer pricing guidance . . .

Europe

Greece enacts corporate tax rate reduction, other support measures

Emmanouela Kolovetsiou-Baliafa, KG Law Firm, discusses a Greek law retroactively reducing the corporate income tax rate, suspending of the special solidarity contribution (SSC), and introducing other support measures that were published in the Official Gazette on May 18 . . .

Digital Economy

Ukraine passes ‘Google tax’ law impacting non-resident digital service providers