More News–MNE Tax

Asia-Pacific

Japan–Serbia tax treaty to enter into force

November 8, 2021

The governments of Japan and Serbia on November 5 completed the necessary exchange of diplomatic notes for the entry into force of the tax treaty between the two countries that was signed in July 2020 and will generally have effect beginning in . . .

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

November 4, 2021

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Asia-Pacific

Cairn and India to resolve long-running tax dispute

November 3, 2021

On November 3, UK-based Cairn Energy announced that it is engaging with the Indian government, under the provisions of the recent Indian legislation withdrawing a controversial retroactive tax law, to resolve its more than USD 1 billion tax dispute with the country and obtain . . .

Asia-Pacific

Singapore finance minister explains why global tax deal is a ‘challenging development’

November 2, 2021

In a November 1 reply to a parliamentary question about potential revenue gains under the OECD global tax deal, Singapore’s Minister for Finance Lawrence Wong explained that such estimates are not so simple and, moreover, the agreement presents some challenges for . . .

Accounting

American Institute of CPAs suggests Congress reconsider corporate minimum tax

November 2, 2021

The corporate minimum tax included in the budget reconciliation bill would create undue complexity and alter financial accounting decision making, according to an October 28 letter from the AICPA to lead congressional tax writers, saying this type of tax . . .

Americas

UK consults on introduction of corporate re-domiciliation regime

November 2, 2021

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Europe

UK to update diverted profits tax for MAP relief, relieving provisions

October 29, 2021

The UK government will adopt legislative amendments to include the diverted profits tax among the taxes for which relief may be granted under the mutual agreement procedure (MAP) of an applicable tax treaty, according to an October 27 policy paper released in connection with . . .

Asia-Pacific

Bahrain tax guide reviews mutual agreement procedure

October 26, 2021

Bahrain’s National Bureau of Revenue in September issued guidance on the mutual agreement procedure (MAP) for resolving international tax and transfer pricing disputes; it is intended to. . .

Europe

Ireland tax guide reviews mandatory disclosure regime

October 25, 2021

Irish Revenue on October 22 incorporated into its tax manual guidelines on the mandatory disclosure regime, setting out guidance notes regarding the required reporting of certain transactions that are . . .

Asia-Pacific

Singapore updates tax treaty guide to address arbitration

October 25, 2021

The Inland Revenue Authority of Singapore on October 23 issued a revised edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax treaties.

Asia-Pacific

Thailand adopts new tax incentives for industry and automation investments

October 21, 2021

The Thailand Board of Investment on October 11 approved new tax incentives to encourage companies to invest in productivity enhancement and automation to speed up its “Industry 4.0” initiative, including . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Americas

US IRS outlines R&D tax credit claim information requirements

October 18, 2021

New guidance from the Internal Revenue Service specifies information that taxpayers must provide when filing research and development (R&D) tax credit claims for their claims to be . . .

Accounting

US IRS again defers applicability of rules on foreign-currency branch income

October 12, 2021

On October 12, the US Internal Revenue Service announced that it would amend certain regulations on the taxable income of “qualified business units,” such as foreign branches, that operate in a foreign currency to delay their applicability for . . .

Americas

Trinidad and Tobago proposes tax incentives for R&D, digital, foreign investment

October 11, 2021

The 2022 budget statement presented by the finance minister of Trinidad and Tobago on October 4 includes several business tax measures, including incentives for digital sector start-ups, a research and development (R&D) capital allowance, and a reduced . . .

Europe

UK R&D tax credit claims continue rapid growth

October 8, 2021

The total number of UK research and development (R&D) tax credit claims for the year ending March 2020 was up 16% from the previous year, and has doubled in the past five years, according to government statistics released September 30.

Europe

EU will not take UK to court over Gibraltar tax-related state aid

October 7, 2021

The European Commission on October 6 announced that it has decided to repeal its decision to refer the UK to the European Court of Justice over Gibraltar’s failure to . . .

Asia-Pacific

Hong Kong plans tax changes to get off EU’s ‘gray list’

October 6, 2021

The government of Hong Kong on October 5 responded to the EU’s inclusion of Hong Kong in its updated “gray list” of jurisdictions that do not yet comply with certain international tax standards, stating that it . . .

Europe

‘Polish Deal’ tax reform passes lower house

October 6, 2021

The “Polish Deal” corporate tax bill on October 4 moved to the Senate after the Polish parliament’s lower house (Sejm) approved the bill, which includes changes to transfer pricing regulations, a new . . .

Africa

EU removes three jurisdictions from tax ‘black list’

October 5, 2021

The European Council on October 5 approved the removal of Anguilla, Dominica, and Seychelles from the EU’s list of non-cooperative jurisdictions for tax purposes, the so-called “black list,” and moving . . .

Americas

Argentina to end tax on exported services

October 1, 2021

The Argentine government announced on September 24 that it will eliminate the tax on exported services beginning in . . .

Accounting

US House budget bill would postpone R&D tax expensing change

September 29, 2021

The reconciliation bill that passed the House Budget Committee on September 25 includes an amendment to delay for four years the requirement for companies to amortize research and development (R&D) expenditures beginning in . . .

Asia-Pacific

Australian Taxation Office reacts to loss in Glencore transfer pricing case

September 28, 2021

The Australian Taxation Office, in a September 28 decision impact statement, sets out its views on the outcome of the Glencore transfer pricing dispute, in which the Federal Court of Australia held that the ATO had misapplied . . .

Americas

Yellen defends corporate tax rate hikes as modest by historical standards

September 28, 2021

The Biden Administration’s proposed increases in corporate taxes would leave corporate tax rates in the US lower than they were at any point between World War II and the 2017 Tax Cuts and Jobs Act, Treasury Secretary Janet Yellen told the National Association for Business Economics on September 28, noting that . . .

Africa

Kenya’s minimum tax ruled unconstitutional, government to appeal

September 23, 2021

The Kenyan High Court in Machakos on September 20 held that the minimum tax on business revenues introduced in the country earlier this year was unconstitutional because it would subject taxpayers to . . .

Asia-Pacific

Philippines introduces digital services tax

September 22, 2021

The Philippines House of Representatives on September 21 approved a 12% value-added tax (VAT) on digital transactions that will apply to foreign corporations selling digital services in . . .

Accounting

US IRS finalizes rules on qualified business asset investment calculations, NOL carrybacks

September 22, 2021

On September 21, the IRS published final regulations on calculating qualified business asset investment (QBAI) under the global intangible-low taxed income (GILTI) and foreign-derived intangible income (FDII) provisions, along with . . .

Denmark

Denmark plans permanent enhanced R&D tax deduction

September 20, 2021

The Danish government proposed to make permanent the current temporary increased deduction for corporate research and development (R&D) expenditures as part of an economic and social plan announced on September 7 . . .

Asia-Pacific

Australia plans to add 10 new tax treaties in next two years

September 17, 2021

Australia plans to expand its existing network of 45 bilateral tax treaties by entering into 10 new and updated tax treaties by 2023, according to a September 15 announcement from . . .

Europe

Ireland 2022 budget strategy papers address corporate, international tax policies

September 16, 2021

The Irish Department of Finance on September 16 published a series of papers examining tax policy in advance of Budget 2022, including issues related to corporate tax and international . . .

Europe

Finland budget includes corporate tax, R&D, transfer pricing proposals

September 14, 2021

Finnish Prime Minister Sanni Marin’s 2022 budget proposes several tax provisions impacting corporations with an aim to encourage investment and economic growth in the country, as reported in a September 9 release from . . .

Asia-Pacific

UK–Taiwan tax treaty protocol signed

September 13, 2021

On September 13, the UK government published an amending protocol to the tax treaty between the UK and Taiwan, which would amend the . . .

Americas

US IRS updates foreign tax credit agency guidance

September 1, 2021

An IRS practice unit published September 1 reviews the rules with respect to the foreign tax credit for businesses, including key concepts, eligible taxpayers, and qualifying taxes – updating the content to reflect . . .

Asia-Pacific

Singapore tax agency rules on taxpayers’ hybrid instruments

September 1, 2021

The Inland Revenue Authority of Singapore on September 1 published two income tax advance rulings (10/2021, 11/2021) concluding that certain securities are debt securities under the . . .

Asia-Pacific

Taiwan tax agency advises on trading gains from foreign exchange options

August 31, 2021

An August 31 statement from Taiwan’s Ministry of Finance states that companies with trading gains from trading foreign exchange options must include those gains in taxable income, explaining that companies . . .

Americas

Canada explains rules on eligibility of work for R&D tax incentives

August 27, 2021

The Canadian government updated its guidelines on the eligibility of work for scientific research and experimental development (SR&ED) tax incentives on August 13 to clarify and provide simplified explanations to help taxpayers better understand SR&ED incentives and . . .

Asia-Pacific

Australian bill introduced to require tax reporting by digital platforms

August 26, 2021

Legislation introduced in Australia’s House of Representatives on August 25 would require digital platform operators to report to the Australian Taxation Office certain information on . . .

Accounting

Russia clarifies R&D expense accounting for tax purposes, associated reporting

August 25, 2021

The Russian Ministry of Finance on July 20 published guidance on the procedure for accounting for research and development (R&D) expenses for income tax purposes under article 262 of the Russian tax code (Letter No 03-03-06/1/49733, dated June 24), and also covers . . .

Europe

UK uncertain tax treatment guidance clarifies new reporting requirement

August 19, 2021

The UK government on August 19 published guidance relating to the upcoming uncertain tax treatment notification requirement for large businesses, following the July 20 release of . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

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