More News–MNE Tax

Asia-Pacific

Singapore–Serbia tax treaty enters into force

August 16, 2021

The double tax treaty signed earlier this year between the governments of Singapore and Serbia entered into force on August 16 and will generally have effect beginning in . . .

Accounting

South African tax bill would amend rules on interest deductibility, assessed losses

August 2, 2021

On July 28, the South African Revenue Service and National Treasury released various draft tax bills that would enhance the rules relating to the limitation on interest deductions on payments to persons not subject to tax and would restrict the set-off of the

Africa

Switzerland and Ethiopia sign tax treaty

July 30, 2021

The governments of Switzerland and Ethiopia signed a double tax treaty on July 29 in . . .

Digital Economy

UK consults on tax information reporting by digital platforms

July 30, 2021

On July 30, the UK HMRC opened a consultation on rules to require digital platforms to report to the tax authority information relating to the . . .

Americas

US, UK competent authorities address tax treaty’s limitation-on-benefits article

July 28, 2021

The US Internal Revenue Service on July 28 published two competent authority arrangements between the US and the UK that clarify the application of the limitation on benefits article in light of the UK’s exit from the EU (Brexit) and the entry into force of the US–Mexico–Canada Agreement (USMCA).

Accounting

US IRS explains tax rules for MNE branch income in a foreign currency

July 28, 2021

A practice unit published by the US Internal Revenue Service on July 26 describes the rules applicable to US multinational enterprises that enter into foreign currency transactions through . . .

Asia-Pacific

South Korean tax reform proposal includes enhanced R&D incentives

July 27, 2021

A tax reform bill introduced by the South Korean government on July 26 includes research and development (R&D) measures aimed at promoting . . .

Asia-Pacific

Singapore–Indonesia updated tax treaty enters into force

July 23, 2021

An updated tax treaty between Singapore and Indonesia entered into force on July 23, replacing . . .

Europe

European R&D tax incentive study proposes harmonizing EU approach

July 21, 2021

A July 1 study from The European Law Institute reviews diverging trends in Europe in the definition of “research and development” (R&D) and “R&D expenditures” for tax purposes and suggests . . .

Americas

US IRS advises on transfer pricing adjustments for Altera-related ‘reverse claw-backs’

July 21, 2021

A US Internal Revenue Service Office of Chief Counsel memorandum published on July 16 offers taxpayer advice with respect to transfer pricing issues related to cost sharing agreements containing “reverse claw-back” provisions, which operate . . .

Asia-Pacific

Japan and Switzerland sign tax treaty protocol

July 16, 2021

Japan and Switzerland on July 16 signed an amending protocol to the tax treaty between the countries that would revise the treatment of taxes on investment income, among . . .

Asia-Pacific

Australia consults on patent box R&D tax incentive

July 13, 2021

The Australian government on July 5 launched a consultation on the design of its planned patent box regime announced in the . . .

Accounting

US IRS explains steps to adjust for tax R&D costs reported in financial statements

July 9, 2021

A practice unit issued by the US Internal Revenue Service on July 7 walks through the steps for large business & international (LB&I) taxpayers to adjust research and development (R&D) expenses reported in . . .

Asia-Pacific

Australian draft tax ruling clarifies when software gives rise to royalties

July 8, 2021

Draft guidance issued by the Australian Taxation Office on June 25 describes the circumstances under which receipts from the licensing and distribution of software will . . .

Asia-Pacific

Thai Board of Investment offers enhanced R&D tax incentives

July 7, 2021

The Thai Board of Investment on June 30 approved several measures to encourage further investment in research and development (R&D), including . . .

Americas

Japan–Uruguay tax treaty enters into force July 23

June 24, 2021

The tax treaty signed by the governments of Japan and Uruguay on September 13, 2019, will enter into force. . .

Americas

US Senate Finance Committee Chair Wyden investigates AbbVie’s international tax practices

June 3, 2021

US Senate Finance Committee Chair Ron Wyden, D-Ore., on June 2 began an investigation into AbbVie’s international tax strategies and accused the biopharmaceutical company of . . .

Asia-Pacific

Singapore declines to limit tax on imported low-value goods

June 2, 2021

The Inland Revenue Authority of Singapore (IRAS) on May 28 announced that it will not adopt several requested changes to the scope of the tax on imported low-value . . .

Asia-Pacific

Cormann takes over at OECD, says global tax deal likely

June 2, 2021

Mathias Cormann took office June 1 as the sixth Secretary-General of the OECD . . .

More News

US Senate committee advances bill to overhaul clean energy tax incentives

June 2, 2021

The Senate Finance Committee on May 26 advanced a comprehensive clean energy bill that would overhaul the current system of energy-related tax . . .

More News

24+ US business groups launch offensive against Biden tax hikes

June 2, 2021

More than two dozen groups representing US companies have joined together to fight US President Joe Biden’s tax hikes on companies and . . .

Belgium

EU Tax Observatory’s first report predicts amounts to be collected under a minimum tax

June 2, 2021

The European Commission on June 1 announced the launch of the European Tax Observatory, an independent, EU-financed research laboratory to study and advise . . .

Europe

Russian law denounces tax treaty with Netherlands

May 27, 2021

Russian President Vladimir Putin on May 26 signed a law denouncing the treaty for the avoidance of double taxation between Russia and the Netherlands that was signed in Moscow in 1996 . . .

Accounting

India to launch e-filing taxpayer portal on June 7

May 27, 2021

The Indian government is planning to launch its new e-filing taxpayer portal on June 7, the Finance Ministry announced . . .

Americas

US pharmaceutical R&D driven partly by tax incentives, CBO report concludes

May 27, 2021

Pharmaceutical spending on research and development (R&D) in the US has increased substantially in recent decades, with changes driven by numerous factors, including R&D tax incentives; however, how the US’s 2017 tax reform will affect R&D investment is uncertain . . .

Asia-Pacific

Australia launches R&D tax incentive customer portal

May 26, 2021

The Australian Tax Office has launched a new customer portal to make it easier for companies to apply for the country’s R&D tax incentive . . .

Europe

UK R&D tax incentives need overhaul to improve effectiveness, study concludes

May 26, 2021

The UK’s research and development (R&D) tax incentive policies have generated a poor return in terms of increased R&D investments, but there are ways to make the incentives more effective while saving taxpayer money, according to a study . . .

Asia-Pacific

Taiwan imposes late filing penalties on foreign businesses selling electronic services

May 26, 2021

Foreign businesses selling cross-border electronic services to individuals in the Republic of China (Taiwan) that fail to timely file required income tax returns for 2020 by June 30 will be subject to . . .

Asia-Pacific

Malaysia tax authority announces changes to country-by-country reporting

May 26, 2021

The Malaysian government announced on May 25 on its website that taxpayers can now file their country-by-country reporting information using . . .

Europe

Poland provides details on coming R&D, innovation tax incentives

May 25, 2021

The Polish Ministry of Finance on May 24 announced details of its tax plan for boosting innovation in Poland, including enhancements to the research and development (R&D) credit and increased deductions . . .

Accounting

India government extends tax filing deadlines because of pandemic: Central Board of Direct Taxes→

May 25, 2021

Americas

US agencies propose tax rule for depository institutions in consolidated groups

May 24, 2021

Depository institutions in consolidated groups would be required to enter into “tax allocation agreements” with other members of their group that join in the filing of a consolidated tax return under a proposed rule published May 10 . . .

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→

May 20, 2021

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OECD report details its efforts to help developing countries during COVID-19

May 19, 2021

The OECD unveiled a report on May 19 detailing its efforts over the past year to help developing countries create better tax policy measures, maximize revenue collection . . .

Americas

US IRS advises on inclusion of royalties in subsidiary’s five-year projection under cost sharing agreement

May 18, 2021

In unofficial advice, the IRS Office of Chief Counsel advised on circumstances when a taxpayer may not need to include any royalties in its five-year projection for a US subsidiary . . .

Accounting

AICPA urges US Congress to clarify international tax provisions

May 13, 2021

The American Institute of CPAs (AICPA) urged US Congress on May 7 to correct and clarify current international tax provisions in the Internal Revenue Code . . .

Accounting

US IRS revises guidance on accounting method changes for controlled foreign corporations

May 12, 2021

The US IRS on May 11 released guidance that aims to make it easier for controlled foreign corporations to . . .

Europe

Finland to remove VAT exemption for imported purchases

May 11, 2021

The Finnish government plans to remove a value-added tax (VAT) exemption for small imported online purchases in July, Finland’s Ministry of Finance announced May 6 . . .

Asia-Pacific

Taiwan offers tax “rewards” for businesses filing account documents electronically

May 11, 2021

Profit-seeking enterprises in the Republic of China (Taiwan) can receive “rewards” for providing all account books and documents electronically using the internet or multimedia, according to a May 6 announcement . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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