More News–MNE Tax

Asia-Pacific

Singapore rules on tax treatment of hybrid securities

May 5, 2021

The Inland Revenue Authority of Singapore ruled that securities issued by a Singapore-based company constituted “debt securities” under the rules characterizing hybrid instruments in two rulings issued May 3 . . .

Asia-Pacific

Taiwan stipulates filing requirement for foreign businesses selling electronic services

May 4, 2021

Certain foreign businesses earning income from cross-border electronic services sold to individuals in the Republic of China (Taiwan) must file income tax returns for 2020 through the online “eTax Portal” . . .

More News

US senators query whether former attorney general Barr stalled Caterpillar tax investigation

May 4, 2021

US Senate Finance Committee Chair Ron Wyden, D-Ore., and Senator Sheldon Whitehouse, D-R.I., launched an investigation on April 28 into whether Trump administration interference stalled a tax investigation of Caterpillar . . .

Accounting

New US tax schedules allow enhanced international tax reporting for pass-throughs

May 4, 2021

The US Treasury Department and the IRS, on April 30, released early release drafts of redesigned schedules K-2 and K-3 for forms 1065, 1120-S, and 8865 for tax year 2021 . . .

Europe

Singapore and Serbia sign income tax treaty

May 4, 2021

Singapore and Serbia have signed an income tax treaty, Singapore’s Inland Revenue Authority announced on May 3 . . .

Europe

Ireland amends R&D tax credit guidance to address rental costs

May 3, 2021

An updated version of Irish Revenue’s tax guidance on the research and development (R&D) tax credit, released April 28, adds a section on rent as a qualifying expenditure for R&D activities, among a few other revisions.

Asia-Pacific

New Zealand enhances R&D tax credit refundability to lessen impact of COVID-19

May 3, 2021

New Zealand’s Inland Revenue has brought forward by one year the application date of broader refundability for the R&D tax credit in a move intended to help businesses retain their R&D capability during the COVID-19 outbreak, the government said . . .

Asia-Pacific

Australian tax guidance clarifies compliance with imported hybrid mismatch rules

April 21, 2021

The Australian Taxation Office issued draft guidance on April 21 regarding its assessment of compliance with the imported hybrid mismatch rules. The guidance is intended to help taxpayers prepare for compliance reviews. The imported hybrid mismatch rules aim to prevent taxpayers from entering

Accounting

FASB to host virtual credit loss panel

April 21, 2021

The Financial Accounting Standards Board (FASB) announced on April 20 that it will host a virtual roundtable next month on implementing the current . . .

Accounting

FASB appoints three members to small business advisory committee

April 21, 2021

The Financial Accounting Standards Board (FASB) on April 20 announced the appointment of three new members . . .

Digital Economy

OECD report looks at impact of digitalization of tax administrations in dealing with the COVID-19 crisis, assessing taxpayer services, compliance risk management, remote working, IT systems, support for wider government: OECD→

April 21, 2021

Belgium

ECJ to rule on whether DAC 6 tax reporting obligation infringes rights

April 21, 2021

A Belgian court has requested a preliminary ruling from the European Court of Justice with respect to whether certain fundamental EU rights are infringed by a provision of DAC 6, which requires mandatory automatic exchange of information in the field of taxation in

Europe

UK tables amendments to hybrid rules

April 20, 2021

The UK government, on April 15, tabled for the Committee of the Whole House amendments to Finance Bill 2021 relating to the corporate tax rules on hybrids and other mismatches . . .

More News

Democrat bill aimed at fossil fuel industry would eliminate tax credits and subsidies, restrict deductions: Senator Edward J. Markey→

April 19, 2021

Americas

IRS asks for public input on priorities for tax guidance

April 19, 2021

The IRS has released an advance version of Notice 2021-28 that invites recommendations for items to be included in the 2021-2022– Priority Guidance Plan. The 2021–2022 Priority Guidance Plan will identify tax guidance projects that the Treasury Department and the IRS intend to

More News

International Compliance Assurance Programme (ICAP) FAQs provided: OECD Forum on Tax Administration→

April 18, 2021

Americas

JCT provides overview of US tax system: Joint Committee on Taxation →

April 16, 2021

Americas

IRS warns taxpayers on microcaptive insurance arrangements

April 14, 2021

Participants involved in abusive microcaptive insurance arrangements should exit the transactions now and not attempt to claim associated deductions on their 2020 tax returns, the IRS said in an April 9 statement. . .

Asia-Pacific

Taiwan advises sellers of digital goods and services to apply for tax registration

March 30, 2021

Individuals who use online platforms or social media software to sell goods or services for profit must apply for tax registration. Taiwan’s National Taxation Bureau of Kaohsiung, Ministry of Finance, said on March 26. . .

Digital Economy

EU Parliament committee adopts resolution on digital taxation

March 30, 2021

The European Parliament’s Committee on Economic and Monetary Affairs (ECON) on March 23 adopted a motion for a European Parliament resolution on digital taxation, OECD negotiations, tax residency of digital companies, and a possible European digital tax. . .

Africa

OECD details 30 countries’ approach to cross-border tax dispute arbitration

March 25, 2021

The OECD today added information to its website on 30 countries’ processes for arbitrating cross-border tax . . .

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Americas

Jose E. Murillo named US Deputy Assistant Secretary for International Tax Affairs

March 2, 2021

The US Treasury Department announced today that Jose E. Murillo has been appointed the new Deputy Assistant Secretary for . . .

Europe

Ireland updates DAC-6 rules on mandatory disclosure of cross-border arrangements

March 1, 2021

Irish Tax and Customs on March 1 updated its Tax and Duty manual section Part 33-03-03 providing guidance on reportable cross-border arrangements. The updated guidance removes the practice of allowing an intermediary not to disclose information about a person to whom they made

Americas

Laurence H. Tribe will represent Coca-Cola in transfer pricing dispute with the US IRS: The Coca Cola Company→

February 24, 2021

Asia-Pacific

Japan-Spain tax treaty to enter into force in May

February 19, 2021

Japan and Spain recently completed the necessary steps . . .

Africa

UN model treaty draft article 12B allows developing countries to use more straightforward domestic rules to tax the digital economy, WBG staff writes: World Bank Group→

February 17, 2021

Asia-Pacific

Japan, Switzerland agree to amend tax treaty

February 8, 2021

The government of Japan and the Swiss Federal Council have agreed in . . .

Americas

US, Argentina agree to exchange country-by-country reports on large multinationals

January 28, 2021

The US and Argentina have signed a competent authority agreement to exchange . . .

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 . . .

Americas

Mark Mazur confirmed as US assistant secretary for tax policy

January 25, 2021

Mark Mazur, director of the Urban-Brookings Tax Policy Center and a former US Treasury Department assistant secretary for tax policy in the Obama administration, is the Biden administration’s new . . .

Estonia

Estonia joins BEPS multilateral tax treaty

January 19, 2021

Estonia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty . .

Digital Economy

EU seeks public input to design of digital levy

January 14, 2021

The EU Commission today requested feedback on the design of its coming . . .

Asia-Pacific

Taiwan offers foreign businesses advance rulings on tax liability

January 4, 2021

Taiwan’s tax authority on January 4 announced that foreign businesses that do not have a . . .

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

January 4, 2021

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Asia-Pacific

Hong Kong, Serbia tax agreement enters into force

January 4, 2021

A comprehensive agreement providing for the avoidance of double taxation entered into force between Hong Kong . . .

Asia-Pacific

Germany and Pakistan deposit instruments of ratification for BEPS MLI with the OECD, joining 57 other countries; entry into force is April 1, 2021, for both countries: OECD→

December 21, 2020

Americas

Cayman Islands amends country-by-country reporting guidance and schema

December 21, 2020

The Cayman Islands on December 17 issued amended country-by-country reporting . . .

Asia-Pacific

Japan, Switzerland to negotiate tax treaty amendments

December 15, 2020

Japan’s Ministry of Finance today announced that the government of Japan and the Swiss . . .

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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

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