Multinational

Americas

COVID-19 and tax treaties: the updated OECD guidance

January 27, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader at GTS (Global Tax Services) UAE, discusses the OECD’s updated guidance on COVID-19 and tax issues, issued January 21 . . .

Europe

EU should better monitor tax information exchange to ensure data quality, encourage states to put tax data to better use, plug gaps such as lack of reporting for cryptocurrencies. ECA says: European Court of Auditors→

January 27, 2021

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

January 25, 2021

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

January 25, 2021

Africa

Transfer pricing and the cumulative advertising effects on sales

January 20, 2021

Dr. Ednaldo Silva, founder and managing director of RoyaltyStat, Bethesda, Md., discusses the effect of advertising on enterprise-level sales, arguing that marketing intangible producing activities such as advertising expenses cannot coexist with the legal concept of limited function distributor or retailer . . .

Digital Economy

EU Commission to soon publish Communication on Business Taxation for the 21st Century, will propose digital levy mid-2021: Valdis Dombrovskis / European Commission→

January 19, 2021

Estonia

Estonia joins BEPS multilateral tax treaty

January 19, 2021

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

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

January 19, 2021

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Americas

Day 2 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

OECD adds transfer pricing country profiles for Argentina, Dominican Republic: OECD→

January 15, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

January 13, 2021

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

January 13, 2021

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Americas

US IRS issues agent guide on qualified dividends and capital gains rate differential adjustments: Internal Revenue Service→

January 5, 2021

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Practical obstacles prevent low-income countries from participating in global tax standard-setting through Inclusive Framework, authors say: Rasmus Corlin Christensen, Martin Hearson, & Tovony Randriamanalina / The International Centre for Tax and Development→

December 21, 2020

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

First Look: OECD guidance examines transfer pricing issues created by the COVID-19 pandemic

December 18, 2020

Today, the OECD published guidance on transfer pricing issues that arise or may be exacerbated on . . .

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020

Africa

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

December 15, 2020

Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

December 14, 2020

Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→

December 11, 2020

Africa

Transactional profit indicators for the TNMM are not viable

December 9, 2020

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

December 9, 2020

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

88% of countries engaging in automatic exchange of financial account information have satisfactory legal frameworks, Global Forum peer review concludes: OECD→

December 9, 2020

Multinational

Report on consumption tax trends notes that most OECD countries have adopted recommended standards for collection of VAT on online sales from offshore vendors: OECD→

December 4, 2020

Digital Economy

UN tax committee releases official report on outcome of 21st session: Committee of Experts on International Cooperation in Tax Matters→

December 2, 2020

Africa

OECD toolkit helps developing country tax administrations satisfy confidentiality and data security requirements for automatic exchange of information with other countries: OECD→

December 2, 2020

Africa

Shell releases 2019 country-by-country report disclosing revenue, profits, tax paid in 98 countries: Shell.com→

November 30, 2020

Inclusive Framework on BEPS

Professor concludes that the OECD pillar one & two proposals would be significant reform that responds to identified flaws in the international tax system: Craig Elliffe / SSRN→

November 30, 2020

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

Americas

France cancels suspension of digital service tax collection, sends Facebook, Amazon, other large tech firms tax bills due in December: Reuters→

November 25, 2020

Africa

NGO report estimates annual corporate tax avoided per country, says USD 245 billion lost annually from MNEs shifting profits to tax havens: Tax Justice Network→

November 25, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

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