More News–MNE Tax

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Policy Paper: Transfer pricing documentation

Kenya

New CbC Reporting Requirements to Apply in Kenya

In a bid to curb profit shifting, Kenya is increasing its transfer pricing documentation requirements. The recently published Kenya Finance Bill seeks to have the ultimate parent entity of a multinational enterprise group or a constituent entity of a multinational enterprise group (MNE’s), which is a tax resident in Kenya, file a country-by-country report.

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Frustrated with Congress, Intel delays chips groundbreaking ceremony

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The Functional Analysis—What You Need to Know

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How International Organizations are Changing Transfer Pricing Compliance

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UK delays Pillar 2 of global tax rules to December

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The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report

Asia-Pacific

Singapore Telecommunications (Singtel) has filed an appeal after Australian court ruled its subsidiary must pay an AUD 393 million tax bill that leads back to the company’s acquisition of Optus in 2001: The Edge Markets→

Kyrgyzstan

Kyrgyzstan, Slovak Republic agree on draft of income tax treaty: AKIpress→

Africa

Belize and Cameroon deposit instruments of ratification for BEPS MLI with the OECD; entry into force is August 1, for both countries; Japan extends the application of the multilateral BEPS convention: OECD→

Americas

US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→

Americas

Assistant Secretary for Tax Policy Lily Batchelder says Biden Administration is optimistic that the US will enact Pillar Two in 2022; global corporate tax would stabilize international tax landscape, make it fairer for US workers and businesses: Lily Batchelder / US Department of the Treasury→

Europe

Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→

G20

OECD seeks public comments by April 29 on extractives exclusion under Amount A of Pillar One. The extractives exclusion will exclude from the scope of Amount A the profits from extractive activities: OECD→

Americas

OECD unveils stage 2 peer review assessments under BEPS Action 14 regarding mutual agreement procedure (MAP) for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau, Morocco and Tunisia: OECD→

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OECD releases public comments received on the implementation framework of the global minimum tax. Public consultation meeting will be held virtually on April 25: OECD→

International Monetary Fund

New IMF Fiscal Monitor: Chapter 2: Coordinating Taxation Across Borders report says a large portion of MNEs’ profit (representing 9.2 percent of global GDP) reflects excess profit (potentially reaching 60 percent of that total profit), which is efficient to tax because it does not distort investment decisions: International Monetary Fund→

Europe

Ireland revises guidance on mandatory disclosure of reportable cross-border arrangements (DAC6) to reflect changes introduced in Finance Act 2021 and to provide additional guidance on various hallmarks, filing obligations, nexus, and the main benefit test: Irish Revenue→

Americas

US Securities and Exchange Commission rules against Amazon’s attempts to exclude a shareholder proposal urging greater global tax transparency; the SEC rules Amazon must include the proposal at its annual investor meeting in May; the move boosts the growing movement of investors in support of public country-by-country reporting: Chris Boose / Fact Coalition→

Americas

US Senate Finance Committee Chair Ron Wyden and Senate Finance Committee Member Rob Portman release bipartisan bill to disallow foreign tax credits for companies that pay taxes to Russia, other tax benefits: United States Senate Committee on Finance→

Americas

US Internal Revenue Service has suspended tax information exchanges with Russian tax authorities in response to Russian war against Ukraine; no information has been shared since Feb. 24 invasion: David Lawder / Reuters→

Accounting

US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→

Austria

Recent corporate tax trends in EU countries: Cristina Enache / Tax Foundation→

Europe

Poland blocks EU agreement on introduction of a minimum 15% corporate tax rate for multinationals with an annual turnover of EUR 750 million or more; 26 member states agreed to the bill, Poland was the only country not to support it; Ecofin to try again in May: Leigh Thomas / Reuters→

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OECD seeks public comments by April 20 on draft rules for scope under Amount A of Pillar One to ensure Amount A only applies to large and highly profitable groups: OECD→

Africa

Egypt, Qatar to revise income tax treaty: Egypt Today→

Asia-Pacific

Thailand deposits BEPS MLI ratification documents with OECD; the multilateral treaty will enter into force on July 1, 2022; 71 jurisdictions have now ratified, accepted, or approved the MLI: OECD→

Americas

US IRS releases 2021 report on US APAs: 145 new APA requests (5% of total number of applications filed over 30 years (1991-2021); 124 APAs were executed in 2021 (out of which 78 were renewals of already existing agreements); most APAs focused on tangible goods or provision of services: Internal Revenue Service→

Digital Economy

OECD releases IT-format to support exchange of tax information on digital platform sellers: OECD→

Americas

US President Biden’s budget raises corporate tax rate from 21% to 28%, contains measures to help ensure MNEs operating in US cannot use tax havens to undercut proposed global minimum tax: Joe Biden / Whitehouse.gov→

Asia-Pacific

Turkish parliament to begin debating draft law this week that could raise corporate tax on financial sector companies from 20% to 25%, and potential prison terms for media outlets that harm firms’ reputations: Reuters→

Africa

Japan-Morocco income tax treaty to enter into force on April 23, 2022: Japanese Ministry of Finance→

Europe

UK Chancellor delivers Spring Statement, pledges to cut tax rates on business investment in autumn budget, confirms UK is considering making R&D expenditure credit scheme more generous to benefit larger companies: Chancellor Rishi Sunak / HM Treasury→

Africa

As of April, Ghana will require all e-commerce and digital platforms without physical presence in the country to file tax returns, pay monthly taxes at an 18.5% rate: Jonas Nyabor / The Africa Report→

Asia-Pacific

Draft New Zealand tax bill requires accurate information about who the `beneficial owner’ is of a company: Devdiscourse→

Americas

Study contends microeconomic data from firms’ publicly available financial statements show that all dimensions of international tax planning are concentrated in three industries and dominated by a small number of very large firms: Dyreng, Hills, and Markle / SSRN→

Europe

EU’s ATAD 3 `unshell’ directive could be improved to freeze Russian oligarchs’ assets more efficiently by extending additional obligations, including the publication of financial statements and nexus to the register of ultimate beneficial owners: Renáta Bláhová / The Slovak Spectator→

Africa

US Senate Democrat leaders said they were `exploring legislation’ to eliminate the tax credits US companies get for paying taxes in Russia, which would put Russia on a list with Iran, North Korea, Sudan, and Syria: The Hill→

G20

OECD releases latest peer review assessing the actions jurisdictions have taken to prevent tax treaty shopping, other forms of treaty abuse under Action 6 of the OECD/G20 BEPS project: OECD→

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