R&D–MNE Tax

Americas

US IRS outlines R&D tax credit claim information requirements

October 18, 2021

New guidance from the Internal Revenue Service specifies information that taxpayers must provide when filing research and development (R&D) tax credit claims for their claims to be . . .

Americas

Trinidad and Tobago proposes tax incentives for R&D, digital, foreign investment

October 11, 2021

The 2022 budget statement presented by the finance minister of Trinidad and Tobago on October 4 includes several business tax measures, including incentives for digital sector start-ups, a research and development (R&D) capital allowance, and a reduced . . .

Europe

UK R&D tax credit claims continue rapid growth

October 8, 2021

The total number of UK research and development (R&D) tax credit claims for the year ending March 2020 was up 16% from the previous year, and has doubled in the past five years, according to government statistics released September 30.

Europe

‘Polish Deal’ tax reform passes lower house

October 6, 2021

The “Polish Deal” corporate tax bill on October 4 moved to the Senate after the Polish parliament’s lower house (Sejm) approved the bill, which includes changes to transfer pricing regulations, a new . . .

Americas

Switzerland, Estonia, Ireland seek concessions in global tax deal

October 4, 2021

OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive Framework’s July statement referring to . . .

Accounting

US House budget bill would postpone R&D tax expensing change

September 29, 2021

The reconciliation bill that passed the House Budget Committee on September 25 includes an amendment to delay for four years the requirement for companies to amortize research and development (R&D) expenditures beginning in . . .

Denmark

Denmark plans permanent enhanced R&D tax deduction

September 20, 2021

The Danish government proposed to make permanent the current temporary increased deduction for corporate research and development (R&D) expenditures as part of an economic and social plan announced on September 7 . . .

Europe

Finland budget includes corporate tax, R&D, transfer pricing proposals

September 14, 2021

Finnish Prime Minister Sanni Marin’s 2022 budget proposes several tax provisions impacting corporations with an aim to encourage investment and economic growth in the country, as reported in a September 9 release from . . .

Accounting

US IRS priority plan adds tax projects on intangibles, hybrids, R&D

September 10, 2021

The US Internal Revenue Service priority guidance plan for 2021–2022, released September 9, lists several new corporate and international tax guidance projects for the coming year, supplementing . . .

Americas

US R&D tax incentives will be among least generous unless Congress acts, study finds

September 8, 2021

The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a September 7 study from . . .

Accounting

US congressman seeks to delay change in R&D expensing rules

August 31, 2021

In an August 26 letter, Congressman John Larson (D-Conn.) urged House Ways and Means Chairman Richard Neal (D-Mass.) to include in the “chairman’s mark” of the budget reconciliation bill a four-year delay in the upcoming requirement for companies to amortize research and development (R&D) expenditures . . .

Americas

Canada explains rules on eligibility of work for R&D tax incentives

August 27, 2021

The Canadian government updated its guidelines on the eligibility of work for scientific research and experimental development (SR&ED) tax incentives on August 13 to clarify and provide simplified explanations to help taxpayers better understand SR&ED incentives and . . .

Asia-Pacific

South Korean tax revision bill includes incentives to spur economy

August 27, 2021

Ross Harman and Jeongwoo Park, Lee & Ko, discuss the July 26 Korean government’s proposed 2021 tax revision bill, including expanded tax reductions for start-ups, extended job creation tax credits, and enhanced research and development (R&D) tax credits, among . . .

Americas

Amgen transfer pricing dispute – is this Medtronic redux?

August 26, 2021

New York City Economist Dr. J. Harold McClure analyzes the situation surrounding the IRS’s large transfer pricing adjustments for 2010–2015 involving the intercompany pricing between Amgen’s US parent and its Puerto Rican manufacturing affiliate, with issues seeming to mirror those in Medtronic’s . . .

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 . . .

Accounting

Russia clarifies R&D expense accounting for tax purposes, associated reporting

August 25, 2021

The Russian Ministry of Finance on July 20 published guidance on the procedure for accounting for research and development (R&D) expenses for income tax purposes under article 262 of the Russian tax code (Letter No 03-03-06/1/49733, dated June 24), and also covers . . .

Americas

US Senate adopts R&D tax amendment in budget resolution

August 17, 2021

A bipartisan amendment relating to promoting US competitiveness and innovation through expanded tax incentives for research and development (R&D) made it into the US Senate budget resolution adopted on August 11, specifically calling for . . .

Americas

US bill proposing tax on corporate book income could undermine R&D incentives

August 11, 2021

A bill announced by US Senator Elizabeth Warren (D-Mass.) on August 9 would impose a tax on the income that large corporations report to their shareholders with an aim to prevent those corporations from using “loopholes” – including tax incentives, like the research and development (R&D) tax credit . . .

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 . . .

Asia-Pacific

South Korean tax reform proposal includes enhanced R&D incentives

July 27, 2021

A tax reform bill introduced by the South Korean government on July 26 includes research and development (R&D) measures aimed at promoting . . .

Europe

European R&D tax incentive study proposes harmonizing EU approach

July 21, 2021

A July 1 study from The European Law Institute reviews diverging trends in Europe in the definition of “research and development” (R&D) and “R&D expenditures” for tax purposes and suggests . . .

Asia-Pacific

Australia consults on patent box R&D tax incentive

July 13, 2021

The Australian government on July 5 launched a consultation on the design of its planned patent box regime announced in the . . .

Accounting

US IRS explains steps to adjust for tax R&D costs reported in financial statements

July 9, 2021

A practice unit issued by the US Internal Revenue Service on July 7 walks through the steps for large business & international (LB&I) taxpayers to adjust research and development (R&D) expenses reported in . . .

Asia-Pacific

Thai Board of Investment offers enhanced R&D tax incentives

July 7, 2021

The Thai Board of Investment on June 30 approved several measures to encourage further investment in research and development (R&D), including . . .

Europe

Italian revenue agency’s new tax assessment guidelines affect multinationals

July 6, 2021

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss the Italian revenue agency’s May 7 guidelines describing its plans to prevent and fight tax evasion, along with an indication of how it will . . .

Asia-Pacific

Australian R&D tax incentive draft ruling clarifies ‘at risk’ rule

June 29, 2021

A draft tax ruling issued by the Australian Taxation Office on June 25 explains the circumstances in which a company’s research and development (R&D) tax offset could be . . .

Americas

US Senate approves bill with R&D funding for semiconductor industry

June 17, 2021

The US Senate passed with bipartisan support on June 8 a bill that would authorize new funding for research and development (R&D) to boost . . .

Americas

Biden will craft R&D tax incentives with congressional input

June 17, 2021

US Treasury Secretary Janet Yellen said during a June 16 Senate Finance hearing that strengthening tax incentives for research and development (R&D) . . .

Americas

Biden tax plan sets aside money for R&D incentives, but details lacking

June 9, 2021

The Biden Administration proposes to enhance incentives for research and development (R&D) using revenue repurposed from the proposed repeal of the deduction for foreign-derived intangible income (FDII), according to . . .

More News

US Senate committee advances bill to overhaul clean energy tax incentives

June 2, 2021

The Senate Finance Committee on May 26 advanced a comprehensive clean energy bill that would overhaul the current system of energy-related tax . . .

Asia-Pacific

South Korea expands R&D tax breaks to bolster semiconductor industry

June 2, 2021

The Republic of Korea signaled its intention to heavily boost its semiconductor industry with an announcement on May 13 that it will offer up to 50 percent tax credits on research and development (R&D) investment and up to 20 percent . . .

Americas

US Treasury ‘Green Book’ details Biden’s international tax plans

May 28, 2021

The US Treasury’s Green Book, released today alongside President Biden’s FY 2022 Budget, outlines the specific tax provisions that the Administration seeks to enact this year, including significant proposals for overhauling . . .

Americas

US pharmaceutical R&D driven partly by tax incentives, CBO report concludes

May 27, 2021

Pharmaceutical spending on research and development (R&D) in the US has increased substantially in recent decades, with changes driven by numerous factors, including R&D tax incentives; however, how the US’s 2017 tax reform will affect R&D investment is uncertain . . .

Asia-Pacific

Australia launches R&D tax incentive customer portal

May 26, 2021

The Australian Tax Office has launched a new customer portal to make it easier for companies to apply for the country’s R&D tax incentive . . .

Europe

UK R&D tax incentives need overhaul to improve effectiveness, study concludes

May 26, 2021

The UK’s research and development (R&D) tax incentive policies have generated a poor return in terms of increased R&D investments, but there are ways to make the incentives more effective while saving taxpayer money, according to a study . . .

Europe

Poland provides details on coming R&D, innovation tax incentives

May 25, 2021

The Polish Ministry of Finance on May 24 announced details of its tax plan for boosting innovation in Poland, including enhancements to the research and development (R&D) credit and increased deductions . . .

Europe

Poland plans enhanced R&D tax incentives in economic recovery effort

May 20, 2021

The Polish Ministry of Finance announced on May 5 various tax plans, including enhanced research and development incentives, in connection . . .

Europe

Italy to introduce 20% R&D credit for work on drugs, including COVID-19 vaccines, if company grants non-exclusive licenses to third-parties: Reuters→

May 20, 2021

Europe

EU report finds states could improve policies on R&D incentives, tax avoidance

May 19, 2021

The European Commission’s Annual Report on Taxation 2021, released May 18, finds that EU member states have made progress in bringing their tax policies in line with EU priorities, but areas for improvement remain . . .

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

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