Latest

Speaking virtually at a July 13 Tax Policy Center event, Grace Perez-Navarro, Deputy Director of the OECD’s Centre for Tax Policy and Administration, explained that the new transfer pricing allocation rules recently endorsed by 130+ countries partially set aside the arm’s length principle but do not . . .

Asia-Pacific

Australia consults on patent box R&D tax incentive

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

Americas

Latin America tax transparency report finds region committed to tackling tax evasion through implementing tax information exchange standards, but the tools are not yet widely used: OECD→

Europe

Poland proposes changes to transfer pricing regulations

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s June 28 launch of taxpayer-friendly amendments to its transfer pricing regulations, including changes to regulations introduced in 2019 that . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Asia-Pacific

Jordan implements formal transfer pricing rules

July 12, 2021

Nour Ali, DNV, discusses Jordan’s June 7 adoption of official transfer pricing rules for the first time through regulation No. 40 of 2021, implementing . . .

Belgium

Belgium proposes tax bill on foreign loss deductions

July 12, 2021

Moïse Gnakouri, Catholic University of Louvain, discusses the Belgian government’s May 27 draft bill that would change the income tax code regarding the conditions for deducting losses realized by . . .

Accounting

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

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 . . .

Multinational

OECD ‘brochure’ touts two-pillar international tax reform plan as solution to estimated USD 100-240 billion in revenues that countries worldwide lose annually to corporate tax avoidance: OECD→

Americas

US Republican lawmakers send Treasury Secretary Yellen letter pressing for harder stance in favor of pro-US terms in international tax negotiations: Senator Mike Crapo (R-Idaho) and Congressman Kevin Brady (R-Texas)→

Europe

Luxembourg government contests press reports about tax authorities accepting as binding informal tax rulings authored by taxpayers or their advisors: Luxembourg Ministry of Finance→

Africa

African Tax Administration Forum welcomes July 1 consensus on international tax reform as including important developments for African countries but cautions against coercing developing countries: ATAF→

Europe

EU digital levy to be proposed July 20 will consist of 0.3% tax on goods and services sold online by companies in EU with turnover of at least EUR 50 million (USD 59 million): Bjarke Smith-Meyer / Politico→

Asia-Pacific

Australian draft tax ruling clarifies when software gives rise to royalties

Draft guidance issued by the Australian Taxation Office on June 25 describes the circumstances under which receipts from the licensing and distribution of software will . . .

Accounting

Australian Accounting Standards Board clarifies deferred tax recognition rules

The Australian Accounting Standards Board (AASB) on July 2 amended its guidance on accounting for deferred tax with respect to transactions that give rise to . . .

Asia-Pacific

UK-based Cairn Energy garners court order in France to seize Indian government property valued at more than EUR 20 million in enforcement of international arbitration award: Tribune India→

Accounting

FASB considering enhanced income tax disclosures on global tax risks

A June 24 consultation on US Financial Accounting Standards Board (FASB) priorities shows the group is looking into enhanced income tax disclosures, including . . .

Asia-Pacific

Thai Board of Investment offers enhanced R&D tax incentives

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

Accounting

Ireland consults on tax rules relating to interest limitation, hybrids

On July 2, the Irish Department of Finance opened for comment tax statements on the anti-reverse hybrid rule and interest limitation ratio rule, which will transpose requirements of the . . .

Asia-Pacific

Taiwan Ministry of Finance reminds businesses claiming foreign tax credits to ensure foreign tax liability should not have been reduced or exempted under applicable tax treaty: R.O.C. Ministry of Finance→

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Americas

US bill introduced in House to zero out base erosion and anti-abuse tax (BEAT) liability temporarily for 2020 as pandemic relief: Congressman Andy Kim (D-NJ)→

Europe

Italian revenue agency’s new tax assessment guidelines affect multinationals

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

Pakistan 2021-22 budget’s tax and economic measures: a friend or foe

Muhammad Khurram Shabbir, Ph.D. student, NUML Islamabad, discusses Pakistan’s budget, released on June 11, which cuts the capital gains tax, removes a series of withholding taxes . . .

Asia-Pacific

Qatar extends transfer pricing filing deadline to 30 September

Rubeena Dina, Global Tax Services, discusses Qatar’s June 17 announcement extending the deadline to file master and local files for the fiscal year ending December 31, 2020 . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Thank you to our MNE Tax founder and community as we grow our platform

July 1, 2021

We are launching an exciting new chapter at MNE Tax, expanding our content and community of expert contributors in collaboration with our new parent CrossBorder Solutions. We would not have gotten to this point without . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Americas

US IRS ‘practice unit’ explains rules applicable to foreign tax redeterminations when a change in a taxpayer’s foreign tax liability affects previously claimed foreign tax credits: Internal Revenue Service→

June 30, 2021

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Europe

Italian tax authorities accuse Booking.com of VAT fraud

June 30, 2021

Daniele Majorana, MICCINESI Tax, discusses the Italian finance police’s June 10 announcement of an investigation into whether online travel agency Booking.com evaded payment of around EUR 153 million (USD 182 million) in value-added tax (VAT) . . .

Americas

US Treasury Secretary stresses importance of India’s support for ‘robust global minimum tax’ in call with Indian Finance Minister: U.S. Treasury→

Americas

Argentina’s Economy Minister says 15% rate for global minimum corporate tax is too low, seeks rate of 21%–25%: Buenos Aires Times→

Europe

EU’s new VAT rules on online shopping enter into force July 1, affecting online sellers and platforms located both in and outside the EU: European Commission→

Accounting

FASB asks members to give feedback on group’s priorities, goals

The Financial Accounting Standards Board (FASB) on June 24 urged members to share their views on the group’s future agenda priorities and goals . . .

Europe

Dutch report on international tax and transfer pricing rulings reflects new ruling practice

Clive Jie-A-Joen and Monique van Herksen, Simmons & Simmons LLP, analyze the June 15 Dutch Revenue Service’s 2020 annual report on international tax rulings, focusing particularly on the advance pricing agreements that . . .

Europe

Spain amends MAP rules for tax and transfer pricing disputes

Mario Ortega Calle and Íñigo García Fernández, J&A Garrigues, S.L.P., discuss Spain’s June 8 approval of Royal Decree 399/2021, improving its mutual agreement procedure (MAP) for resolving double taxation . . .

Asia-Pacific

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