What We're Reading

Americas

Coca-Cola’s tax liability in transfer pricing dispute over intangible property licenses could be 12 billion, company reports: David Allison / Atlanta Business Chronicle→

February 10, 2021

Europe

EU Code of Conduct Group (Business Taxation) publishes work program for Portuguese Presidency: European Council→

February 10, 2021

Americas

Fordham University law professor Rebecca Kysar appointed Counselor to the Assistant Secretary, Office of Tax Policy: US Treasury Department→

February 10, 2021

Americas

Maryland bill would prohibit tech companies subject to new digital advertising tax from charging the purchaser a separate fee to cover the tax: Danielle E. Gaines / Maryland Matters→

February 10, 2021

Americas

Georgetown professor Itai Grinberg to be new US Deputy Assistant Secretary for Multilateral Tax Office of Tax Policy: US Department of Treasury→

February 10, 2021

Americas

Kimberly Clausing appointed US Deputy Assistant Secretary for Tax Analysis, Office of Tax Policy: US Department of the Treasury→

February 10, 2021

Asia-Pacific

Maldives provides English translation of country-by-country reporting regulations: Maldives Inland Revenue Authority→

February 10, 2021

Digital Economy

UK exploring options for new tax on online sales: Sky News→

February 10, 2021

Europe

Ireland updates tax guidance on company residence to reflect the end of transition period provided in the Finance Act 2014: Irish Tax and Customs→

February 10, 2021

Europe

EU digital tax proposals are unwarranted and flawed, tax policy group argues: Daniel Bunn / Tax Foundation→

February 9, 2021

Asia-Pacific

India files suit in Singapore High Court challenging Vodafone arbitration award: ET Telecom→

February 8, 2021

Americas

Bermuda lists jurisdictions treated as reportable jurisdictions for country-by-country reporting: Bermuda Ministry of Finance, Treaty Unit→

February 8, 2021

Multinational

Using a novel measurement approach, professors conclude that Pillar One and Two blueprint rules are more complex than existing OECD and UN transfer pricing guidance: Jean-Edouard Colliard, Lorraine Eden, & Pierre Georg / SSRN→

February 8, 2021

Multinational

UN tax committee publishes practices and working methods agreed to at its October 2020 meeting: United Nations Committee of Experts on International Cooperation in Tax Matters→

February 3, 2021

Americas

EU Commission’s grounds for appeal in Apple State aid tax case published: European Court of Justice→

February 3, 2021

Asia-Pacific

Australia says top international MNE compliance risks are profit shifting, related party debt, service hubs, inbound supply chain pricing, PE avoidance, non-arm’s length intangibles arrangements, outbound PE, foreign disposal of property: Australian Taxation Office→

February 3, 2021

Americas

Professor highlights importance of third-party asset valuation to protect US tax system from abuse: Leandra Lederman / SSRN→

February 3, 2021

Europe

Guernsey advises financial intuitions of new country-by-country reporting schema and reporting requirements: States of Guernsey Revenue Service→

February 2, 2021

Europe

Guernsey informs reporting entities of country-by-country reporting schema change and reporting requirements: States of Guernsey Revenue Service→

February 2, 2021

Americas

US IRS large business and international unit adds compliance campaigns on Puerto Rico individual investors act, taxable asset transactions: Internal Revenue Service→

February 2, 2021

Asia-Pacific

Australia confirms that compliance resources will not be used to determine existence of PE in some instances where employees are present due to COVID-19: Australian Taxation Office→

February 2, 2021

Asia-Pacific

Tax ruling addresses whether use of a Singapore investment company’s foreign-sourced dividend income from a related foreign investment company to offset a non-trade related intercompany debt triggers remittance rules: Inland Revenue Service of Singapore→

February 2, 2021

Americas

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

January 28, 2021

Americas

US Democrat senators introduce bill applying GILTI on a per-country basis, eliminating companies’ ability to deduct 10 percent of their tangible assets before GILTI applies: Sen. Amy Klobuchar→

January 28, 2021

Asia-Pacific

Hong Kong laws granting profits tax concessions for insurance-related business and setting March 19 the law’s effective date were gazetted, government notes: Hong Kong government→

January 28, 2021

Americas

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

January 27, 2021

Americas

In a call to German minister Scholz, new US Treasury secretary pledges active US participation in OECD international taxation effort “to forge a timely international accord”: US Department of Treasury→

January 27, 2021

Europe

EU should better monitor tax information exchange to ensure data quality, encourage states to put tax data to better use, plug gaps such as lack of reporting for cryptocurrencies. ECA says: European Court of Auditors→

January 27, 2021

Europe

Ireland updates DAC6 guidance to clarify filing procedure when a disclosure is subject to legal privilege: Irish Tax and Revenue→

January 27, 2021

Americas

US seeks feedback on burdens of reporting foreign currency transactions: IRS / Federal Register→

January 27, 2021

Asia-Pacific

Cairn Energy threatens to seize Indian government assets overseas to enforce 1.2 billion tax arbitration award: Aditi Shah & Aftab Ahmed / Reuters→

January 26, 2021

Americas

Janet Yellen sworn in as US Treasury secretary

January 26, 2021

Janet Yellen was sworn in Tuesday as the 78th Treasury secretary in US history . . .

Digital Economy

Amazon to increase fees of Spanish companies that use its platform in response to imposition of 3 percent DST: Reuters→

January 25, 2021

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

January 25, 2021

Americas

US IRS solicits comments on whether treaty-based return position disclosures are burdensome: Internal Revenue Service / Federal Register→

January 25, 2021

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

January 25, 2021

Asia-Pacific

Australian guidance addresses how investors holding hybrid securities on capital account determine market value when there is a buy-back or redemption: Australian Taxation Office→

January 22, 2021

Asia-Pacific

China should consider new tax on tech companies, securities regulation official and former vice finance minister say: Cheng Siwei, YU Hairong, Zhang Erchi, and Denise Jia / Nikkei Asia→

January 20, 2021

Americas

US Treasury nominee Yellen would delay corporate rate increase because COVID recovery takes priority, would work with OECD to stop tax “race to the bottom”: Thomas Franck / CNBC→

January 20, 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