What We're Reading–MNE Tax

Americas

Professor assesses Pillar One Amount A impact per country, industry: Lorraine Eden / SSRN→

Americas

Assessing business reaction to the TCJA and its guidance, GAO concludes that future international tax rulemaking should better assess paperwork burden and economic effects on business: General Accounting Office→

Europe

Switzerland will continue to operate as a highly attractive business location despite global tax deal, finance ministry says: Reuters→

Europe

Ireland’s new VAT rules for goods arriving into Ireland from non-EU countries enter into effect July 1, government notes: Irish Revenue→

Americas

UK finance minister says US plan to break global tax deadlock could work: William Schomberg / Reuters→

Americas

Cyprus to oppose global min tax, EU public country-by-country reporting: eKathimerini.com→

Asia-Pacific

Australia updates and extends through year-end its guidance on whether a PE is created from the presence of employees in Australia due to COVID-19: Australian Taxation Office→

Europe

EU states should increase cooperation on corporate tax rates and base to reduce tax competition and avoidance irrespective of any global agreement, IMF paper concludes: International Monetary Fund→

Asia-Pacific

Australia, UK agree on how to apply the arbitration provisions added via the MLI to their tax treaty: Australian Taxation Office→

Asia-Pacific

MLI’s changes to Singapore-Malaysia tax treaty took effect June 1, government notes: Inland Revenue of Singapore→

Africa

Israel, United Arab Emirates sign tax treaty: Reuters→

United States

US employers group says Biden Administration’s plan to increase GILTI rate will kill jobs: PACE Coalition→

India

India disputes media claims regarding actions it allegedly took to avoid payment of arbitration award in Cairn Energy tax dispute, reasserts legal challenges to arbitral decision: Government of India→

Asia-Pacific

Saudi Arabia merges tax and customs authorities into single agency: Asharq Al-Awsat→

Americas

Global tax deal should forbid DSTs, equalization levies, and DPTs and should define a broad, uniform tax base for the global minimum tax: Daniel Bunn / Tax Foundation→

Africa

South Africa guidance addresses taxation of foreign dividends other than dividends paid by a headquarters company: South Africa Revenue Service→

United Kingdom

UK Labour Party to force vote on US global minimum tax proposal to push government to support plan: Reuters→

Europe

EU Parliament approves Fiscalis programme to provide EUR 269 million over seven years to help EU tax administrations build capacity to share information and better enforce EU tax law: European Parliament→

Americas

US CRS publishes updated report summarizing US corporate tax trends and proposals: Congressional Research Services→

Europe

Commission recommends EU states grant up to EUR 3 million carryback of losses to at least 2019 to help businesses that have suffered from COVID-19 pandemic : EU Commission→

OECD

Pillar One compromises to gain US and broader consensus likely mean any agreement would bring limited gains in terms of fairness, efficiency, and administrability, professor says: Aitor Navarro / SSRN→

Americas

New Zealand will levy digital services tax on locally-derived revenues of Google, Facebook if no OECD accord is reached, Revenue Minister says: Jonathan Milne / newsroom.pro→

Americas

Canadian officials again warn US that they plan to impose a digital services tax in 2022 unless global tax agreement is reached: Reuters→

Europe

Ireland likely to oppose EU plan for unified tax base: Eoin Burke-Kennedy / The Irish Times→

Europe

Italy to introduce 20% R&D credit for work on drugs, including COVID-19 vaccines, if company grants non-exclusive licenses to third-parties: Reuters→

Americas

UK firm Cairn Energy sues Air India to enforce a USD 1.2 billion arbitration award in tax dispute against India: Euan Rocha & Jonathan Stempel / Reuters→

Azerbaijan

Japan, Azerbaijan to begin negotiations May 20 for new tax treaty to replace 1986 treaty: Japan Ministry of Finance→

Americas

Hearing scheduled next week on Lily Batchelder’s nomination as Treasury’s assistant secretary for tax policy: US Senate Finance Committee→

Asia-Pacific

Jordan extends postponement of 2 percent tax on imports: Ministry of Digital Economy and Imports→

Americas

US Supreme Court allows challenge to microcaptive insurance reporting requirements to proceed: Andrew G. Simpson / Insurance Journal→

Europe

Luxembourg welcomes EU court’s judgment that Amazon tax treatment did not violate state aid law, will “examine” judgment finding state-aid advantage in ENGIE case: Luxembourg Government→

Africa

If US and EU states can convince large emerging economies to adopt GloBE, MNEs will pay double-digit billions more tax, face increased complexity, Professor says: Joachim Englisch / SSRN→

Europe

Perrigo in discussions to settle $1.9B Irish tax bill, dispute concerns IP sales taxed as trading income at 12.5% instead of 33%: Seeking Alpha→

Asia-Pacific

Australia amends permanent establishment guidance to address situations where employees are forced to remain in Australia due to COVID-19: Australian Taxation Office→

Americas

Chile’s lower house approves progressive tax on lithium, copper with rates potentially exceeding 32 percent: Andrea Hotter / Fastmarkets→

Europe

European Court of Human Rights upholds EUR 1,000 (USD 1,200) fine against ex-PricewaterhouseCoopers employees for providing tax returns to journalists in LuxLeaks scandal: Molly Quell / Courthouse News Service→

Americas

US lawmakers reintroduce public country-by-country reporting bill: Rep. Cynthia Axne→

Americas

Argentina extends transfer pricing deadlines due to COVID-19: AFIP (in Spanish)→

Europe

ECJ to this week hear Luxembourg’s appeal of the General Court’s decision in Fiat which approved the Commission’s use of the arm’s length principle to determine if a tax ruling gives rise to State aid: Seán McCárthaigh / Irish Times→

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