What We're Reading–MNE Tax

Americas

Chip Harter, US Treasury deputy assistant secretary for international tax affairs, to leave his post this month: Bernie Becker / POLITICO→

November 16, 2020

Europe

Malta releases DAC6 XML Schema and user guide for reporting cross-border arrangements: Office of the Commissioner of Revenue→

November 16, 2020

Americas

US IRS corrects final regs limiting deduction for dividends from foreign corporations: Federal Register→

November 13, 2020

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 2020

Africa

South Africa extends deadlines to file country-by-country reports: South African Revenue Service→

November 13, 2020

Asia-Pacific

Malaysia provides English-language translation of guidance outlining procedure for appealing tax assessments: Inland Revenue Board of Malaysia→

November 12, 2020

Digital Economy

Nations must agree to tax regime for digital firms that produces “a fair tax system that provides long-term sustainable revenues” or the EU will make its own proposal, von der Leyen says: European Commission→

November 12, 2020

Europe

Guernsey extends country-by-country reporting filing deadlines for constituent entities because of COVID-19: States of Guernsey→

November 12, 2020

Europe

Ireland updates guidance on R&D tax credit refunds: Irish Tax and Customs→

November 11, 2020

Asia-Pacific

Vietnam minister notes government effort to determine foreign streaming services revenue to assess additional tax: Yahoo finance→

November 10, 2020

Europe

Luxembourg and Russia sign treaty raising tax on dividends, interest: Yannick Lambert / Luxembourg Times→

November 10, 2020

Australia

Australia revamps R&D taxation guidance: Minister for the Department of Industry, Science, Energy, and Resources→

November 10, 2020

Americas

US issues final and temporary regs on gain or loss from foreign persons from sale of partnership interests: Federal Register→

November 6, 2020

Europe

Irish High Court rejects Perrigo’s challenge to procedural issues unrelated to merits of USD 1.9 billion tax case involving tax rate applicable to IP sales: Conor Humphries / Reuters→

November 4, 2020

Europe

Ireland provides guidance on DAC6 reporting of cross-border arrangements: Irish Tax and Customs→

November 3, 2020

Americas

US IRS again corrects FDII and GILTI regs: Federal Register→

November 3, 2020

Europe

Commission opinion asserts that Spain has missed deadline to transpose hybrid mismatch directive into law and threatens lawsuit unless action is taken within two months: European Commission→

November 2, 2020

Europe

Commission asks France to change taxation of foreign investment fund capital gains arising from sales of French company shares: EU Commission→

November 2, 2020

Europe

EU Commission refers Greece to Court of Justice over rules that provide different tax treatment for losses incurred domestically and those incurred in other EU/EEA state: EU Commission→

November 2, 2020

Europe

CJEU rules that EU freedom of establishment does not preclude application of Romanian transfer pricing law imputing market-rate interest on loan between parent and branch located in another state: Court of Justice of the European Union→

October 30, 2020

Asia-Pacific

Sri Lanka publishes new transfer pricing disclosure form and guide: Sri Lanka Inland Revenue→

October 30, 2020

Americas

US IRS limits taxpayers’ ability to “telescope” results of MAP and APA negotiations into current tax year, requiring taxpayers to instead amend prior years’ returns: Internal Revenue Service→

October 29, 2020

Europe

Of 39 large EU banks, 31 operate in tax havens and 29 report large profits in countries where no employees are located, suggesting profit shifting, new report concludes: Elena Gaita & Linda Kunertova / Transparency International EU→

October 29, 2020

Europe

Spanish draft budget proposes to limit large MNEs’ tax exemption for dividends and capital gains from subsidiaries, tax real estate investment trusts: Carlos E. Cue & Laura Delle Femmine / El Pais→

October 28, 2020

Americas

US corrects final FDII and GILTI regs: Federal Register→

October 28, 2020

Multinational

UN tax subcommittee PowerPoint shows plan for new handbook for policymakers on carbon tax: United Nations→

October 28, 2020

Europe

Professors analyze EU General Court decision in Apple, noting drawbacks of using state aid concept to counter MNE tax avoidance: Stephen Daly, Ruth Mason / SSRN→

October 27, 2020

Digital Economy

Author proposes international taxation regime for cross border cloud computing businesses: Alexander Weisser / UNIGE→

October 27, 2020

Americas

Final US regs address absorption of NOL carryovers, carrybacks and update rules on consolidated groups that include life insurance and other companies: Federal Register→

October 27, 2020

Africa

South Africa presidential commission recommends adoption of digital tax, tax on processed metals, R&D tax credit incentive: Businesstech→

October 27, 2020

Americas

16 business groups urge Mexico to drop proposal to cut non-residents’ internet connection if they fail to comply with new tax registration rules: SIIA→

October 26, 2020

Digital Economy

OECD’s pillar 1 & 2 impact assessment reveals the value of reaching global agreement versus descending into a tax and trade wars: Daniel Bunn / Tax Foundation→

October 21, 2020

Multinational

Professor analyzes Australian tax authority’s transfer pricing reconstruction power as a tool to combat IP migration, focusing on Amazon case, OECD guidelines: Anthony Ting / SSRN→

October 19, 2020

Multinational

Professors propose home-country tax on MNEs that pay low effective rates: Kimberly A. Clausing, Emmanuel Saez, Gabriel Zucman / SSRN→

October 16, 2020

Americas

Cayman Islands to propose changes to pending LLP law to improve its “commercial functionality” prior to the regime becoming operational: Cayman Finance→

October 16, 2020

Digital Economy

Facebook’s cryptocurrency, Libra, presents tax policy challenges, authors note: Allison Christians & Mahwish Tazeem→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Russia tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Korea tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Czech Republic tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

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