Latest

MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .

Multinational

Tax complexity for multinational corporations continues to increase, with transfer pricing presenting greatest complexity due to intricate documentation requirements and ambiguous rules, according to new global survey: Accounting for Transparency→

Africa

Irish tax treaty commentators disagree on approach to new negotiations

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

United States

US corporations pay lower effective tax rate than their foreign competitors and would likely continue to under proposed Biden corporate tax rate increase, according to Reuters analysis: Tom Bergin (Reuters) / Nasdaq→

Americas

New OECD toolkit guides Latin American and Caribbean tax authorities on applying value-added tax to e-commerce activities: OECD→

Canada

Canada updates guidance on competent authority procedures for taxpayers trying to resolve issues relating to double taxation or taxation not in accordance with an applicable tax treaty: Canada Revenue Agency→

Georgia

Japan–Georgia tax treaty signed January 29 will enter into force on July 23 following June 23 exchange of diplomatic notes: Japan Ministry of Finance→

Europe

Russian tax authorities clarify application of domestic general anti-avoidance rules

Alexey Ryabov, JTI Russia, discusses Russian tax guidance issued on March 11 establishing criteria for applying the general anti-avoidance rule under Article 54.1 of the tax code aimed at . . .

Accounting

US IRS allows accounting method changes for depreciation of certain real property

On June 17, the US Internal Revenue Service provided guidance (Revenue Procedure 2021-28) explaining how a taxpayer changes its method of computing depreciation for residential rental property held by . . .

Africa

G20 draft communique reportedly endorses global minimum tax

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Digital Economy

OECD develops exchange framework for digital platform tax reporting

The OECD sets out in a June 22 report a multilateral competent authority agreement for the automatic exchange of information relating to income derived by . . .

Europe

EU consults on plan to tackle debt-equity bias in corporate taxation through measures aimed at equalizing tax treatment of debt and equity to be combined with accompanying anti-abuse provisions: European Commission→

Americas

Argentina establishes simplified transfer pricing reporting regime

Hernán Ubertazzi, 3D Asesores, discusses the Argentine tax agency’s June 18 guidance simplifying the transfer pricing reporting regime to alleviate burdens on taxpayers that are considered . . .

Accounting

Finnish court accepts US GAAP as basis for transfer pricing in landmark ruling

Heikki Vesikansa, Jenni Parviainen, and Stefan Stellato, Hannes Snellman Attorneys Ltd., discuss a key June 2 Finnish Supreme Administrative Court ruling (SAC 2021:73), confirming the acceptability of a foreign . . .

China

China may not have much to lose under global corporate minimum tax and could hinge its support on US’s willingness to lift tariffs on Chinese goods: Frank Tang / South China Morning Post→

Ireland

Ireland will seek yet-to-be-defined compromise in global minimum tax talks with aim of preserving room for tax competition by smaller countries, Irish Finance Minster says: Silvia Amaro / CNBC→

United States

US IRS internal training document explains application of global intangible low-taxed income (GILTI) rules, including scope, computation, and allocation: Internal Revenue Service→

Asia-Pacific

China increases tax relief for science and technology companies

Hengka (Henry) JI and Jiannan Zhu, Zhong Lun Law Firm, discuss Chinese government announcements issued March 16 – April 15 implementing tax policies promoting scientific and technological innovation and the development . . .

Mexico

Mexican Finance Secretary and US Treasury Secretary discuss importance of Mexico’s support within G20 for global minimum tax: U.S. Department of Treasury→

United States

US government bipartisan study on corporate tax reform finds that economic distortions caused by corporate taxes have declined over time and could be further reduced by additional changes: Congressional Research Service→

Europe

EU customs regulations will require payment of import turnover tax on goods valued under EUR 22 starting July 1: Austrian Ministry of Finance→

United States

US House passes bill to require public country-by-country reporting by SEC-registered multinational corporations: FACT Coalition→

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) . . .

Europe

Finland court rejects tax authority’s transfer pricing approach to intercompany interest rates

June 17, 2021

New York City Economist Dr. Harold McClure discusses a May 21 Finnish Supreme Administrative Court decision which rejected the Finnish tax authority’s attempt to increase the intercompany interest rates charged by a Finnish financing affiliate to its Russian operating affiliate . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Asia-Pacific

Singapore updates tax guidance for advertising industry: Inland Revenue of Singapore→

Europe

Royalty payments from Ireland to US jumped from about EUR 8 billion (USD 9.6 billion) annually to EUR 52 billion (USD 62.5 billion) in 2020, concludes report published on Irish government website: Seamus Coffey / University College Cork→

Accounting

UK guidance addresses income tax in interim periods

With the 2021 interim reporting season rapidly approaching, the UK’s Financial Reporting Council (FRC) has provided examples companies should follow . . .

Accounting

IASB proposes to overhaul ‘management commentary’

The International Accounting Standards Board (IASB) on May 27 published a new framework proposing to overhaul “management commentary” . . .

Europe

Romania implements new rules for establishing tax residence

Felix Tapai and Oana Săvulescu, MPR Partners, discuss a May 17 Romanian questionnaire affecting foreign legal entities seeking to establish tax residence . . .

Accounting

FASB’s Investor Advisory Committee gives input on emerging issues, trends

The Financial Accounting Standards Board’s (FASB) Investor Advisory Committee met on May 25 to give its input on various FASB topics and trends . . .

Europe

Two EU Parliament committees approve public country-by-country compromise: European Interest→

Europe

Finnish tax administration publishes statements addressing transfer pricing guidelines and effect of COVID-19 on permanent establishment rules