What We're Reading

Asia-Pacific

Australian court holds R&D tax offset refund was paid by mistake, subject to recovery provision

April 8, 2021

The Federal Court of Australia held on March 19 that a research & development tax offset refund claimed by, and paid to, a taxpayer, but to which the taxpayer was not entitled, is subject to . . .

Digital Economy

OECD Secretary-General report to G20 ministers includes overview of 66 countries’ tax policy responses to COVID-19: OECD→

April 7, 2021

Multinational

Professor analyzes OECD model treaty changes regarding entitlement to tax treaty benefits for income received through transparent entities: Leopoldo Parada / SSRN→

April 6, 2021

Americas

US West Virginia Democratic Senator Manchin says he won’t support Biden’s proposed 28% corporate tax hike, that 25% is more appropriate: Alexander Bolton / The Hill→

April 6, 2021

International Monetary Fund

Countries should consider temporary tax on “excess” corporate profits to lessen inequality resulting from Covid-19 pandemic, IMF says: International Monetary Fund→

April 5, 2021

Americas

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

April 5, 2021

Multinational

NGOs ask public for new ideas on ways resource-rich developing countries can maximize tax revenues from mining: Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development→

April 1, 2021

Europe

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

April 1, 2021

Europe

Russia, Luxembourg ratify protocol increasing withholding tax rates for dividends and interest income to 15 percent: Tass→

April 1, 2021

Europe

Ireland updates guidance on capital allowances for intangible assets

April 1, 2021

Irish Revenue updated its tax manual guidance on capital allowances for intangible assets on March 31 to reflect amendments made by Finance Act 2020. . .

Asia-Pacific

Singapore updates guidance on business foreign exchange gains or losses: Inland Revenue of Singapore→

April 1, 2021

Asia-Pacific

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

April 1, 2021

Americas

US business group urges Congress to pass bill preserving companies’ ability to immediately deduct R&D expenses: US Chamber of Commerce→

March 31, 2021

Americas

IRS releases agent training materials on interest and dividends received from CFCs: Internal Revenue Service→

March 30, 2021

Transfer Pricing

States show renewed interest in transfer pricing agreements: JDSupra→

March 26, 2021

Europe

German cabinet adopts bill closing MNE tax avoidance loopholes

March 26, 2021

Germany’s federal cabinet on March 24 adopted a bill implementing the EU’s Anti-Tax Avoidance Directive, including stricter rules to fight aggressive tax avoidance strategies used by multinational corporations. . .

Americas

US IRS releases agent instruction manual on the Section 965 transition tax on untaxed earnings of foreign corporations: Internal Revenue Service→

March 24, 2021

Europe

Ireland MEP says Parliament proposal to dispense with majority voting on tax issues that “distort” the single market skirt the treaty: Sarah Collins / Independent.ie→

March 24, 2021

Asia-Pacific

India appeals Cairn Energy USD 1.4 billion arbitration award: The Economic Times→

March 23, 2021

Asia-Pacific

India’s lower house passes Finance Bill, 2021: Hindustantimes→

March 23, 2021

Americas

US Senate Finance Committee chairman to unveil bill to overhaul MNE corporate tax: Allan Smith & Kristen Welker / NBC News→

March 19, 2021

Inclusive Framework on BEPS

NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group→

March 18, 2021

Europe

Public country-by-country reporting is inevitable, EU Commission official says: Naomi O’Leary / The Irish Times→

March 18, 2021

Asia-Pacific

Australia and Belgium enter into a memorandum of understanding on procedure for arbitration of tax disputes: Australian Taxation Office→

March 18, 2021

Asia-Pacific

Japanese ministry considers reducing tax burden on Japanese-based tech companies’ overseas earnings: The Mainichi→

March 17, 2021

Europe

Ireland updates guidance on self-certification system allowing payment of interest and royalties with deductions at the applicable tax treaty rate: Irish Tax and Revenue→

March 17, 2021

Africa

South Africa issues private ruling on taxation of transfer of reinsurance business from a resident company to a local branch of a foreign company: South African Revenue Service→

March 16, 2021

Europe

Ireland pays €1 million to the Netherlands for MAP settlement regarding the location of KPN insurance unit’s profits in 2014 and 2015: Mark Paul / The Irish Times→

March 16, 2021

Americas

Biden administration negotiating global minimum tax, expected to raise corporate taxes: Jeff Stein / The Washington Post→

March 16, 2021

Asia-Pacific

Indonesia to cut taxes for hybrid vehicles: Cindy Silviana, Gayatri Suroyo / Reuters→

March 15, 2021

Asia-Pacific

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

March 15, 2021

Europe

UK updates guidance for claiming SME research & development relief noting new form CT600 filing requirement from April 1: HMRC→

March 15, 2021

Americas

NYU law professor Lily Batchelder named US Assistant Secretary for Tax Policy: US Treasury→

March 11, 2021

Americas

Over 100 US legislators support new bill to apply the same tax rate on a company’s overseas profits as on those earned in the US: Lloyd Doggett→

March 11, 2021

Americas

State of Maryland issues guidance on digital products and streaming tax: MD Comptroller→

March 11, 2021

Americas

US corrects final regs (TD 9926), providing guidance related to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the US: IRS→

March 11, 2021

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

What We’re Reading

Australian court holds R&D tax offset refund was paid by mistake, subject to recovery provision

OECD Secretary-General report to G20 ministers includes overview of 66 countries’ tax policy responses to COVID-19: OECD→

Professor analyzes OECD model treaty changes regarding entitlement to tax treaty benefits for income received through transparent entities: Leopoldo Parada / SSRN→

US West Virginia Democratic Senator Manchin says he won’t support Biden’s proposed 28% corporate tax hike, that 25% is more appropriate: Alexander Bolton / The Hill→

Countries should consider temporary tax on “excess” corporate profits to lessen inequality resulting from Covid-19 pandemic, IMF says: International Monetary Fund→

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

NGOs ask public for new ideas on ways resource-rich developing countries can maximize tax revenues from mining: Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development→

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

Russia, Luxembourg ratify protocol increasing withholding tax rates for dividends and interest income to 15 percent: Tass→

Ireland updates guidance on capital allowances for intangible assets

Singapore updates guidance on business foreign exchange gains or losses: Inland Revenue of Singapore→

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

US business group urges Congress to pass bill preserving companies’ ability to immediately deduct R&D expenses: US Chamber of Commerce→

IRS releases agent training materials on interest and dividends received from CFCs: Internal Revenue Service→

States show renewed interest in transfer pricing agreements: JDSupra→

German cabinet adopts bill closing MNE tax avoidance loopholes

Canada’s Supreme Court rules federal carbon tax is constitutional: John Paul Tasker / CBC News→

China to increase extra tax deduction for R&D expenses of manufacturing firms: State Council→

New Zealand parliament passes tax bill

US IRS releases agent instruction manual on the Section 965 transition tax on untaxed earnings of foreign corporations: Internal Revenue Service→

Ireland MEP says Parliament proposal to dispense with majority voting on tax issues that “distort” the single market skirt the treaty: Sarah Collins / Independent.ie→

India appeals Cairn Energy USD 1.4 billion arbitration award: The Economic Times→

India’s lower house passes Finance Bill, 2021: Hindustantimes→

US Senate Finance Committee chairman to unveil bill to overhaul MNE corporate tax: Allan Smith & Kristen Welker / NBC News→

NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group→

Public country-by-country reporting is inevitable, EU Commission official says: Naomi O’Leary / The Irish Times→

Australia and Belgium enter into a memorandum of understanding on procedure for arbitration of tax disputes: Australian Taxation Office→

Japanese ministry considers reducing tax burden on Japanese-based tech companies’ overseas earnings: The Mainichi→

Ireland updates guidance on self-certification system allowing payment of interest and royalties with deductions at the applicable tax treaty rate: Irish Tax and Revenue→

South Africa issues private ruling on taxation of transfer of reinsurance business from a resident company to a local branch of a foreign company: South African Revenue Service→

Ireland pays €1 million to the Netherlands for MAP settlement regarding the location of KPN insurance unit’s profits in 2014 and 2015: Mark Paul / The Irish Times→

Biden administration negotiating global minimum tax, expected to raise corporate taxes: Jeff Stein / The Washington Post→

Indonesia to cut taxes for hybrid vehicles: Cindy Silviana, Gayatri Suroyo / Reuters→

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

UK updates guidance for claiming SME research & development relief noting new form CT600 filing requirement from April 1: HMRC→

NYU law professor Lily Batchelder named US Assistant Secretary for Tax Policy: US Treasury→

Over 100 US legislators support new bill to apply the same tax rate on a company’s overseas profits as on those earned in the US: Lloyd Doggett→

State of Maryland issues guidance on digital products and streaming tax: MD Comptroller→

US corrects final regs (TD 9926), providing guidance related to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in a trade or business within the US: IRS→