Latest

The BEPS Monitoring Group contends in October 5 comments that multinational enterprises that are not in-scope of the global tax deal’s Pillar 1 partial reallocation of taxing rights to market jurisdictions should remain subject to . . .

Asia-Pacific

Hong Kong plans tax changes to get off EU’s ‘gray list’

The government of Hong Kong on October 5 responded to the EU’s inclusion of Hong Kong in its updated “gray list” of jurisdictions that do not yet comply with certain international tax standards, stating that it . . .

Europe

‘Polish Deal’ tax reform passes lower house

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

Mexico proposes new transfer pricing rules of the game

Jesús Aldrin Rojas M., QCG Transfer Pricing Practice, discusses the Mexican government’s September 8 decree that would modify the transfer pricing regime to enhance its effectiveness as a tax collection and audit instrument for the tax authorities, providing new and aggressive rules of the game for . . .

Africa

EU removes three jurisdictions from tax ‘black list’

October 5, 2021

The European Council on October 5 approved the removal of Anguilla, Dominica, and Seychelles from the EU’s list of non-cooperative jurisdictions for tax purposes, the so-called “black list,” and moving . . .

Americas

Dominican Republic introduces country-by-country reporting rule – a decade after transfer pricing documentation obligations entered into force

October 5, 2021

José Rafael Monsalve, transfer pricing economist and international tax advisor, discusses the Dominican Republic’s October 5 release of specific regulations for the country-by-country report – a decade after transfer pricing documentation obligations entered into force – through . . .

Europe

Italy draft guidance clarifies transfer pricing documentation requirements

October 5, 2021

Giuliana Polacco, Annarita De Carne, Francesco Drago and Camilla Cominelli, Studio Legale Bird & Bird, discuss the Italian Revenue Agency’s September 20 publication of the draft of a long-awaited circular letter on transfer pricing, focused on the documentation necessary to verify the correct application . . .

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 . . .

Europe

Greek bill would cut corporate income tax rate by 30% for three years for mergers between small- and medium-sized enterprises: Eirini Chysolora / eKathimerini→

October 4, 2021

Accounting

European accounting group comments on IASB draft subsidiary disclosure requirements

October 1, 2021

The European Financial Reporting Advisory Group (EFRAG) on September 30 published draft comments on the International Accounting Standards Board’s (IASB) July 26 exposure draft that would permit eligible subsidiaries to apply International Financial Reporting Standards (IFRS) with reduced disclosure requirements in their . . .

Americas

Argentina to end tax on exported services

October 1, 2021

The Argentine government announced on September 24 that it will eliminate the tax on exported services beginning in . . .

Europe

Finnish court rules on arm’s length range and transfer pricing adjustment point

October 1, 2021

Heikki Vesikansa, Jenni Parviainen and Stefan Stellato, Hannes Snellman Attorneys Ltd., discuss Finland’s Supreme Administrative Court’s September 13 publication of a year-book decision examining the use of comparable data in determining the arm’s length range and the transfer pricing . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Africa

Multilateral convention to implement tax treaty related measures to prevent BEPS gains 96th signatory in Namibia, will enter into force for Andorra and Spain in January 2022: OECD→

September 30, 2021

Asia-Pacific

Ukraine advances tax treaty protocols with Denmark and Qatar

September 30, 2021

Iryna Kalnytska, GOLAW, discusses the Ukraine government’s September 2 publication of a draft tax law ratifying the protocol to the 1996 tax treaty between Ukraine and Denmark, along with the same day signing of a protocol with . . .

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 . . .

Europe

Poland considers delayed introduction of ‘hidden divided’ non-deductibility concept

September 29, 2021

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Finance Ministry’s September 28 announcement that it might postpone until 2023 its plans to introduce a controversial provision that would limit the deductibility of so-called “hidden dividend” payments as part of the “Polish Deal” tax bill that . . .

Accounting

European Council advances directive on public country-by-country tax reporting

The Council of the European Union on September 28 adopted its position on the proposed directive that would require large multinationals operating in the EU to publicly disclose certain information on the income taxes they pay on a country-by-country . . .

Asia-Pacific

Australian Taxation Office reacts to loss in Glencore transfer pricing case

The Australian Taxation Office, in a September 28 decision impact statement, sets out its views on the outcome of the Glencore transfer pricing dispute, in which the Federal Court of Australia held that the ATO had misapplied . . .

Americas

Yellen defends corporate tax rate hikes as modest by historical standards

The Biden Administration’s proposed increases in corporate taxes would leave corporate tax rates in the US lower than they were at any point between World War II and the 2017 Tax Cuts and Jobs Act, Treasury Secretary Janet Yellen told the National Association for Business Economics on September 28, noting that . . .

Asia-Pacific

Indian decision on COVID-induced forced stay has tax implications for MNEs

Ashish Mehta and Ujjval Gangwal, Khaitan & Co., discuss the Indian Supreme Court’s September 7 decision not to entertain taxpayer petitions seeking an exclusion of COVID-19-induced forced/involuntary stay for financial year 2020-21, for the purpose of . . .

Europe

Ireland reportedly ready to increase corporate tax rate to 15% if OECD agrees to strike from agreement term that global minimum tax be ‘at least’ 15%: Pat Leahy & Cormac McQuinn / Irish Times→

US Democrats’ hopes of overhauling TCJA’s foreign taxes stemmed by global pressure

Alex M. Parker, Capitol Counsel LLC, discusses why the most recent version of the Democrats’ plan for overhauling the US tax code – approved by the House Ways and Means committee on September 15 – suggests the party may be backing down on its promise to repeal a key part of the Tax Cuts and Jobs Act’s . . .

Europe

Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids

Jian-Cheng Ku, Gabriël van Gelder, and Rhys Bane, DLA Piper Nederland N.V., discuss the Dutch government’s September 21 tax proposals for 2022, including several direct tax measures that would affect multinational enterprises, such as limiting unilateral downward transfer pricing adjustments and . . .

Europe

Ukraine Ministry of Finance clarifies general tax consultation on deemed dividends