Multinational

Africa

Most favored nation clauses in tax treaties between high- and lower-income countries operate to the disadvantage of the latter, resulting in significant tax base erosion: Deepak Kapoor / ICTD→

August 26, 2021

Americas

US Senate unveils international tax reform draft legislation

August 25, 2021

Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify key provisions of the Republicans’ 2017 tax law, including the global intangible low-taxed income (GILTI) provision, foreign-derived intangible income (FDII), and . . .

Global minimum tax’s ‘GloBE’ maze – more than meets the eye!

August 25, 2021

Noopur Trivedi and Jitesh Golani, international tax researchers, analyze a hypothetical case study evaluating the effect that the intricate rules under the global anti-base erosion (GloBE) proposal in the July 1 OECD/G20 Inclusive Framework statement can have when implemented in a typical multinational . . .

Europe

Poland corporate tax bill clarifies definition of place of management

August 24, 2021

Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s June 28 launch of a public consultation for a new tax bill called the “Polish Deal,” which includes amendments to regulations that might raise concerns amongst associated companies, such as the broadening . . .

Accounting

Dozen countries deemed ‘highly inflationary’ for accounting standard purposes

August 23, 2021

The Center for Audit Quality, in a report published August 20, flagged 12 economies as potentially highly inflationary for purposes of US GAAP Accounting Standards Codification (ASC) 830, Foreign currency matters.

Americas

Barbados planning measures to counter effect of global minimum tax, including using increased corporate tax revenues to provide R&D grants to companies paying the higher taxes: Marlon Madden / Barbados Today→

August 20, 2021

Europe

Germany adopts substantial transfer pricing and anti-treaty shopping rule changes

August 20, 2021

Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .

Americas

Japan releases study group report on international taxation in the digital economy

August 19, 2021

Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .

Multinational

Share of profits shifted to tax havens remained roughly constant globally (9%–10%) in latest data (2018) despite OECD BEPS implementation and increased in US (19%–23%) despite enactment of 2017 tax law: Thomas Tørsløv, Ludvig Wier & Gabriel Zucman / Missing Profits→

August 18, 2021

Multinational

Tax is ‘a bigger corporate risk than ever’ due to enhanced country-by-country reporting and ongoing global tax talks, investors should be wary of companies that are not transparent about tax dealings: Richard Murphy / International Investment→

August 18, 2021

Morocco publishes mutual agreement procedure guide for resolving tax disputes

August 16, 2021

Nour Ali, DNV, discusses Morocco’s Mutual Agreement Procedure (MAP) guide, released July 5 through the General Tax Administration of the Ministry of Economy and Finance, for resolving tax disputes not in accordance with . . .

Asia-Pacific

Gulf Cooperation Council countries and businesses prepare for global minimum tax

August 16, 2021

Raman Ohri, Keypoint, discusses the dilemma that the July 1 inclusive framework agreement on a global minimum tax created for Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates . . .

Americas

Barbados becomes 133rd country to join global tax agreement, holdouts dwindle to six

August 13, 2021

The agreement on international tax reform that was endorsed by the majority of the 139 “Inclusive Framework” countries on July 1 grew one country stronger on August 12 as Barbados became the latest . . .

Asia-Pacific

Taiwan amends tax treaty rules on residency, permanent establishment, treaty abuse

August 12, 2021

On August 12, Taiwan’s Ministry of Finance promulgated amendments to the regulations governing the application of double tax treaties to update the decade-old rules for developments in international tax trends and conventions, improve administrability, and . . .

Asia-Pacific

Singapore joins multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting: OECD→

August 11, 2021

Africa

Maldives, Papua New Guinea, and Rwanda join multilateral treaty for international tax cooperation and exchange of information: OECD→

August 11, 2021

Multinational

OECD’s ‘Inclusive Framework’ has failed to give developing countries enough of a voice to affect international tax reforms and the resulting discontent will threaten the stability of the international tax regime: Yariv Brauner / SSRN→

August 11, 2021

Americas

Brazil’s upcoming tax reform will impact inbound investors

August 10, 2021

Luis Felipe de Campos, Rolim, Viotti, Goulart, Cardoso Advogados, discusses the substitute tax reform bill that Brazil’s Ministry of Economy presented to Congress on June 25, including provisions affecting corporate tax rates, profit distributions, interest . . .

Accounting

IASB proposes amendment for insurers, European accounting group responds

August 9, 2021

The International Accounting Standards Board (IASB) on July 28 proposed a limited change to the transition requirements in International Financial Reporting Standards (IFRS) 17, Insurance Contracts, intending to address . . .

Americas

US Congress should take up international tax reform without waiting for OECD talks to conclude, because US can benefit from changes regardless of global deal and acting first will strengthen US negotiating position: The FACT Coalition→

August 9, 2021

Asia-Pacific

Hong Kong tax agency advises on tax and transfer pricing effects of Covid-19

August 9, 2021

The Hong Kong Inland Revenue Department on July 29 clarified its approach to the disruptions caused by Covid-19 with respect to various tax issues, including issues related to tax residence, permanent establishment . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Multinational

Exchange of information agreements reduce multinational corporation tax-motivated profit shifting, data study shows, but newer and more advanced agreements do so more effectively: Devan Mescall and Paul Nielsen / Canadian Tax Journal→

August 5, 2021

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Europe

Poland business transfer pricing forum advises on Covid-19 impact

August 3, 2021

Dr. Monika Laskowska at the Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish Ministry of Finance’s July 13 publication for public consultation of recommendations on the impact of Covid-19 on transfer pricing . . .

Asia-Pacific

India’s first year of ‘faceless’ tax assessments runs into legal issues

August 3, 2021

Suranjali Tandon from the National Institute of Public Finance and Policy, New Delhi, analyzes several court decisions issued in June and July that highlight implementation issues with India’s new “faceless” – i.e., digital – tax assessment scheme, which was intended . . .

OECD

Inclusive Framework’s statement on international tax reform does not contain stringent enough terms to ensure MNEs are taxed where economic activity occurs but may be an important step in that direction: The BEPS Monitoring Group→

August 2, 2021

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

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 . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

Global minimum tax could create confusion with current CFC rules

July 28, 2021

Thomas Locher, Tax Foundation’s Center for Global Tax Policy, discusses how the implementation of a global minimum tax could create confusion with current CFC rules, raising questions about . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Europe

Germany introduces new administrative principles for transfer pricing

July 23, 2021

Oliver Treidler, TP&C GmbH, discusses Germany’s July 14 release of new administrative principles for transfer pricing that are effective immediately and will constitute a focal point of the German transfer pricing . . .

Europe

Germany adopts ATAD rules on exit taxation, CFCs, hybrids

July 22, 2021

Timo Turek, partner at Ypsilon International GmbH, discusses Germany’s June 30 implementation of the Anti-Tax Avoidance Directive (ATAD) into law, affecting exit taxation, controlled foreign corporation (CFC) taxation reform, intra-EU anti-hybrid rules, as well as . . .

Asia-Pacific

Oman suspends local filing transfer pricing reporting requirement

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses Oman’s July 7 announcement suspending the country-by-country local filing requirement until . . .

Asia-Pacific

United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses the United Arab Emirates’ July 1 release of mutual agreement procedure (MAP) guidance for resolving tax and transfer pricing disputes through. . .

Americas

Ireland seeks input on OECD tax proposals’ impact on Irish tax policy

July 20, 2021

The Irish Department of Finance on July 20 opened a consultation on implications for Ireland’s corporate tax policy arising from the two-pillar proposal for overhauling the international tax framework recently . . .

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

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