Multinational

Accounting

OECD must engage business advisory group on tax deal implementation, BIAC asserts

November 18, 2021

Continued lack of engagement by the OECD with the business stakeholders represented by “Business at OECD” (BIAC) with respect to implementing rules for the OECD’s global tax deal will result in outcomes that are not administrable, according to a November 16 letter to OECD tax leaders from . . .

Multinational

United Nations tax body is needed to address cross-border tax abuse and reform global tax regulations; OECD deal gave developing countries a voice but didn’t listen: José Antonio Ocampo / Project Syndicate→

November 17, 2021

Africa

International tax-related information exchange generates billions in revenue, Global Forum reports

November 17, 2021

The automatic exchange of financial account information between countries is linked directly to at least EUR 3 billion in additional tax revenues; it also has contributed, through voluntary disclosure and other programs, to more than EUR 112 billion in additional tax revenues, according to a November 17 . . .

Africa

Egypt slowly adopting tax changes on base erosion and profit shifting

November 16, 2021

Sherif Sabakhawy, TAXONOMY, discusses Egypt’s slow-moving steps towards attaining international tax norms outlined in the OECD’s base erosion and profit shifting (BEPS) project . . .

Europe

Irish Finance Minister outlines reasoning in joining global tax deal

November 10, 2021

The benefits to Ireland of joining the OECD/G20 global tax deal “far outweigh” the downsides of remaining outside the deal, which would carry “very real risks,” Irish Finance Minister Paschal Donohoe explained in a November 10 address to . . .

Africa

‘Tax Inspectors Without Borders’ expands developing country tax and transfer pricing assistance

November 9, 2021

Tax Inspectors Without Borders – a joint initiative of the OECD and United Nations Development Programme – expanded the scope of its assistance to developing country tax administrations, according to the initiative’s 2021 annual report released November 9, amid challenges faced by . . .

Asia-Pacific

Jordan publishes executive instructions for transfer pricing rules

November 8, 2021

Nour Ali, DNV, discusses Jordan’s September 16 release of the country’s latest transfer pricing guidance regarding the disclosure form, local file, master file, and country-by-country report, along with specific . . .

Africa

Kenya prefers its digital tax, which hits 89 companies in the country, to global tax deal, which would only hit 11 (exempting Uber and others); also objects, with Nigeria, to deal’s mandatory binding arbitration: Carlos Mureithi / Quartz Africa→

November 5, 2021

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.

Americas

Global minimum tax will work, if implemented, OECD’s Saint-Amans says

November 4, 2021

OECD tax policy director Pascal Saint-Amans in a November 4 interview expressed that the political agreement on a 15% global minimum effective tax rate is a big deal, he is very pleased with the outcome, and he has little fear of companies attempting to exploit loopholes to evade the tax because . . .

Americas

Biden administration’s budget bill tax revenue estimates confirmed, partly

November 4, 2021

The revenue expected to be raised from the tax provisions included in the current draft of the Democrats’ Build Back Better budget is largely in line with the Biden administration’s claims, based on estimates released November 4 by the non-partisan US Congressional . . .

Europe

French transfer pricing case highlights functional analysis at heart of tax litigation

November 4, 2021

Patrick Donsimoni, La Boetie, discusses the French supreme tax court’s October 4 decision, underlining that a group’s transfer pricing policy must be in line with the structuring of its supply chain since the functional analysis is decisive for . . .

Accounting

US budget bill tax provisions’ effective dates, rates, thresholds

November 3, 2021

Following a November 2 off-year election that many pundits consider an initial bad omen for the Democrats, Biden and the party continue to finalize the details – and secure the votes – for the signature portion of the President’s agenda, including several notable corporate and international tax . . .

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 . . .

Asia-Pacific

Spanish Supreme Court denies access to MAP in domestic GAAR tax case

November 2, 2021

Aitor Navarro, Carlos III University, discusses the September 22 Spanish Supreme Court decision regarding SGL Carbon Holding (ECLI:ES:TS:2021:3572), addressing the denial of a mutual agreement procedure (MAP) initiation request on the grounds of tax abuse in a case involving . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Accounting

Canadian accounting board calls for more disclosures on tax and accounting differences

October 29, 2021

The Canadian Accounting Standards Board recommended to the International Accounting Standards Board (IASB) in a letter published October 26 that enhanced disclosure requirements are needed with respect to the relationship between tax expenses and accounting profits, responding to an . . .

Americas

White House’s hopes of an international tax revenue windfall may be overblown

October 29, 2021

Alex M. Parker, Capitol Counsel LLC, discusses how, without the political support for raising tax rates, Democrats are looking to an overhaul of the international tax system to help pay for the USD 1.75 trillion spending package; but some recent estimates say . . .

Americas

Biden ‘confident’ has votes for new tax and spending framework

October 28, 2021

US President Biden announced on October 28 a new framework for his “Build Back Better” bill, which he is now “confident … can pass both houses of Congress,” following . . .

Europe

UK will amend R&D tax reliefs, increase bank corporate tax rate

October 28, 2021

The UK government announced plans to reform tax incentives for research and development (R&D) as well as increase the corporate tax rate for banks as part of the 2021 autumn budget . . .

Accounting

US tax plan shifts, with corporate minimum tax in, rate hikes out

October 27, 2021

Democrats appear poised to adopt for their budget bill a corporate minimum tax of 15% on the book income of the most profitable companies, with an updated proposal for such a tax released October 26 by . . .

Europe

Italy introduces new patent box regime

October 27, 2021

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss Italy’s October 21 repeal and replacement of the former patent box regime, which, from 2021 onwards, shift it from a profit-based incentive to an extra deduction for certain R&D costs incurred by . . .

Americas

Paraguay clarifies transfer pricing rules

October 27, 2021

Horacio Sánchez Pangrazio, FERRERE, discusses Paraguay’s October 14 and September 15 clarifications of its transfer pricing rules, providing further regulation regarding . . .

Africa

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

October 25, 2021

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities’ introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and Africa . . .

Digital Economy

Irish Finance Bill 2021 adopts transfer pricing, international tax changes

October 22, 2021

The Finance Bill 2021 released by the Irish government on October 21 sets out legislative changes related to transfer pricing, anti-tax avoidance measures, planned tax treaty ratifications, and various . . .

Accounting

European digital services taxes to stay for now, with offsetting credits, countries agree

October 21, 2021

Under an October 21 agreement between the United States and Austria, France, Italy, Spain, and the UK, the European countries can keep their existing digital services taxes in place pending implementation of Pillar 1 of the OECD global tax deal; however, multinational groups . . .

Customs

European Commission work programme 2022 includes tax projects

October 21, 2021

The European Commission will work to ensure “swift and consistent” implementation within the EU of the two-pillar global tax agreement to show “EU’s leadership in global tax fairness,” according to its work programme 2022 released October 19, including a new . . .

Platform for Collaboration on Tax shifts priorities in response to global tax deal

October 20, 2021

The Platform for Collaboration on Tax – a joint initiative of the OECD, United Nations, International Monetary Fund, and World Bank Group – is reevaluating its international tax priorities in light of the Inclusive Framework agreement reached . . .

Americas

Bermuda’s tax advantage in (re)insurance industry will diminish under global minimum tax, which will reduce, but not eliminate, gap in effective tax rate between Bermuda and non-Bermuda companies: Fitch Ratings→

October 20, 2021

Africa

Kenya contends revenue threshold for companies subject to Pillar 1 of OECD agreement is too high, lower threshold is needed for developing countries to benefit: Kenya Revenue Authority→

October 20, 2021

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 . . .

Africa

Country-by-country reporting adopted in more than 100 jurisdictions, OECD reports

October 18, 2021

More than 100 jurisdictions have in place a domestic legal framework for requiring country-by-country reporting by large multinational enterprises, according to an OECD report released October 18, noting that additional jurisdictions have . . .

Developing countries need transfer pricing rule simplifications, OECD advises G20

October 18, 2021

The OECD highlights the importance for developing countries of streamlining complex transfer pricing rules and facilitating access to country-by-country reports in October 13 recommendations to . . .

Asia-Pacific

Thailand clarifies its transfer pricing documentation requirements

October 15, 2021

Paul Ashburn and Rohit Sharma, HLB Thailand, discuss Thailand’s September 30 release of a notice on the transfer pricing documentation that corporate taxpayers will be required to provide to support their analysis of the terms of their . . .

Accounting

European accounting group’s top priorities: intangibles, sustainability, crypto

October 14, 2021

The European Financial Reporting Advisory Group (EFRAG) on October 11 recommended to the International Accounting Standards Board (IASB) what it considers to be the highest priority projects for . . .

Europe

EU directive will implement OECD tax deal ‘as is’

October 13, 2021

The European Commission “will try” to deliver in December a directive to implement the OECD tax deal within the EU and that directive “will implement the agreement as is,” according to October 12 comments by Benjamin Angel, Director of the European Commission DG TAXUD, who . . .

Austria

Austria updates transfer pricing guidelines

October 13, 2021

Iris Burgstaller, TPA Austria and Baker Tilly, discusses the Austrian Ministry of Finance’s October 7 publication of the final version of the revised Austrian transfer pricing guidelines, replacing the 2010 guidelines to incorporate OECD developments, particularly the . . .

Accounting

Ireland 2022 budget’s tax changes include 15% corporate rate, new incentives

October 12, 2021

The Irish government’s Budget 2022, announced October 12, includes an increase in the corporate tax rate to 15% in line with last week’s OECD tax agreement, expanded relief for start-up companies, a new tax credit for . . .

Multinational

Global tax pact’s ‘revolution’ builds on old concepts – long-standing apportionment rules between US states in case of Pillar 1 and century-old ‘single tax principle’ in case of Pillar 2: Reuven Avi-Yonah / LinkedIn→

October 12, 2021

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

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