Multinational

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

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 . . .

Europe

UK consults on aligning transfer pricing documentation requirements with OECD approach

March 24, 2021

The UK HM Revenue and Customs is considering potential new transfer pricing documentation requirements that would require businesses to prepare and provide specific documentation to support their transfer pricing . . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Asia-Pacific

Singapore adopts BEPS-compliant IP tax incentives

March 24, 2021

Edmund Leow SC of Dentons Rodyk & Davidson LLP, Singapore, discusses Singapore regulations on its new concessionary income tax rules for intellectual property, which came into effect on January 22. . .

Asia-Pacific

Mongolia’s first transfer pricing assessment – what could be the issues?

March 23, 2021

Dr. J. Harold McClure, New York economist, discusses the issues surrounding Mongolia’s first transfer pricing assessment. . .

Asia-Pacific

Bahrain introduces country-by-country reporting requirements

March 23, 2021

Abdulrahman Bucheeri and Raman Ohri of Keypoint Solutions, Manama, discuss Bahrain ministerial guidance introducing country-by-country reporting requirements, released on February 4 . . .

Americas

US Senate Finance Committee chairman to unveil bill to overhaul MNE corporate tax: Allan Smith & Kristen Welker / NBC News→

March 19, 2021

Asia-Pacific

Mongolia issues first transfer pricing assessment

March 18, 2021

The Mongolian government has issued its first transfer pricing tax assessment, hitting a mining company with a tax bill of approximately USD 228 million and a denial of USD 1.5 billion in carried forward . . .

Inclusive Framework on BEPS

NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group→

March 18, 2021

Americas

Canadian mining company seeks NAFTA arbitration in Mexico transfer pricing dispute

March 17, 2021

First Majestic Silver, a publicly traded Canadian mining company, has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in conflict with the terms of an advance pricing agreement. . .

Americas

Mathias Cormann appointed OECD Secretary General

March 17, 2021

The OECD council on March 15 named former Australian finance minister Mathias Cormann as its next leader beginning in June. He will become the first secretary-general from. . .

Asia-Pacific

Transfer pricing for Indian software distribution affiliates

March 17, 2021

New York City economist, Dr. J. Harold McClure, notes that Indian tax authorities may take a closer look at transfer pricing following their loss in a landmark decision involving the taxation of foreign-based software providers . . .

Africa

EU to implement digital levy regardless of OECD-led effort

March 16, 2021

The EU Commission will continue to press ahead with its proposal for an EU digital levy to fund EU operations even if a global international tax . . .

UN tax committee to issue proposed model treaty language on taxing rights for automated digital services

March 15, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has announced that it is finalizing language on a proposed article for inclusion in the UN Model Tax Convention attributing . . .

Asia-Pacific

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

March 15, 2021

“Platform for Collaboration on Tax” toolkit offers guidance on negotiating tax treaties

March 11, 2021

On March 10, the “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and World Bank Group – launched the final version of its Toolkit on Tax Treaty Negotiations. . .

Americas

Can GILTI and the GloBE be harmonized in a Biden administration?

March 3, 2021

Daniel Bunn, Vice President of Global Projects, Tax Foundation, discusses the need for the US’s GILTI rules and the Inclusive Framework’s GloBE proposal to be harmonized . . .

Americas

US Tax Court decision in Coca-Cola is at odds with economic principles

March 3, 2021

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, Md., identifies flaws in the US Tax Court’s decision in the Coca-Cola transfer pricing dispute . . .

Africa

Zambia introduces country-by-country reporting

March 3, 2021

Rubeena Dina and Kennedy Munyandi, of GTS Africa, discuss the Zambian government’s issuance of transfer pricing regulations addressing country-by-country reporting, which became effective January 1 . . .

G20

OECD releases secretary-general tax report to G20 finance ministers and central bank governors: OECD→

February 26, 2021

Africa

US drops demand that “pillar one” global tax compromise be a safe harbor

February 26, 2021

The US will no longer require that any coordinated “Pillar One” update to the international tax and transfer pricing rules be drafted as a “safe harbor.” The announcement . . .

Multinational

OECD reports on strategies to crack down on professionals who enable tax and white collar crimes: OECD→

February 26, 2021

Europe

ActionAid, Christian Aid Ireland, Oxfam call on Ireland to drop opposition to public country-by-country reporting: Naomi O’Leary / The Irish Times→

February 24, 2021

G20

Biden Deputy Treasury nominee seeks higher corporate tax rates, level playing field for American companies, ending global corporate tax ‘race to the bottom’: Reuters→

February 24, 2021

Africa

Latest updates to EU list of non-cooperative jurisdictions

February 24, 2021

Francesca Amaddeo, a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the February 22 update to the EU’s list of non-cooperative jurisdictions for tax purposes . . .

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Africa

Countries agree to new rules for private tax ruling transparency

February 22, 2021

An OECD-led coalition of 139 countries working together on cross-border tax issues known as the “Inclusive Framework on BEPS” has agreed to a new method for assessing whether countries meet global minimum standards for private tax ruling . . .

Africa

Proposed UN model treaty article on automated digital services is simpler than OECD/G20 Inclusive Framework proposal and preserves taxing rights of developing countries, IMF subcommittee says: International Monetary Fund→

February 19, 2021

Africa

Feedback sought on UN model tax treaty provision clarifying taxation of software payments

February 17, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has released a discussion draft and . . .

Africa

Analysis of MNE data in 34 countries shows that thin capitalization rules, by raising the cost of capital, can significantly affect real investment: International Monetary Fund→

February 17, 2021

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

Digital Economy

Is the EU (unintentionally) undermining ongoing OECD work on digital taxation?

February 17, 2021

Oliver Treidler, TP&C GmbH, discusses the January 14 European Commission inception impact assessment and request for public feedback on the design of an EU digital levy . . .

Africa

OECD publishes assessment of cross-border tax dispute resolution in 13 more countries

February 17, 2021

The OECD on February 1 published assessments of the cross-border tax dispute resolution processes in Aruba, Bahrain . . .

Africa

Stakeholders weigh-in on BEPS Action 14 standards for cross-border tax dispute resolution

February 10, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, discusses an OECD consultation meeting, held February 1, addressing OECD Secretariat proposals with respect to a 2020 review of BEPS Action 14, concerning cross-border tax dispute resolution . . .

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

Africa

First Look: OECD consultation focuses on improving cross-border tax dispute resolution

February 1, 2021

The OECD today hosted a consultation meeting on a planned review of minimum standards, agreed to by OECD and G20 countries in 2015, that aim to improve cross-border tax dispute resolution for multinational . . .

Asia-Pacific

First Look: India’s Budget – A step towards clarity for foreign investor taxation

February 1, 2021

Mukesh Butani and Seema Kejriwal, of BMR Legal in Delhi, take a first look at the Indian government’s budget proposals for 2021–22, released today, focusing on several important proposals that affect international taxation . . .

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.
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