Latest

Investigations into the tax-ruling practices of Iceland, Liechtenstein, and Norway have found no evidence of the countries’ tax rulings being used in violation of state aid rules, according to a June 4 . . .

Americas

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

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 . . .

What's New

Yellen letter to Crapo on OECD tax negotiations

Yellen_letter_to_Crapo_on_OECD_tax_negotiations[920]

Americas

Yellen says global minimum tax is necessary to preserve sovereignty

Harmful international tax competition, unchecked by any minimum tax, has eroded governments’ sovereignty to collect corporate taxes, stripping governments of funds necessary to address urgent fiscal priorities, according to a June 4 letter from US Treasury Secretary Yellen . . .

Digital Economy

Professor says source taxation of nonresident digital businesses is justified because value creation is partly derived from infrastructure and other benefits provided by market jurisdiction: Craig Elliffe / SSRN→

June 8, 2021

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Americas

Coca-Cola says tax court erred in transfer pricing dispute, seeks reconsideration

The Coca-Cola Company on June 2 asked the US Tax Court to reconsider and set aside its November 2020 transfer pricing decision, in which it determined that Coca-Cola’s US income should be increased by . . .

Americas

Professor assesses Pillar One Amount A impact per country, industry: Lorraine Eden / SSRN→

Accounting

UK’s FRC revises auditing standard for auditors’ responsibilities in regards to fraud

The UK’s Financial Reporting Council (FRC) on May 27 issued a revision of its auditing standard on the responsibilities of auditors relating to fraud. Revisions in ISA (UK) 240 (Revised May 2021) – The Auditor’s responsibilities Relating to Fraud in an Audit of

Americas

Assessing business reaction to the TCJA and its guidance, GAO concludes that future international tax rulemaking should better assess paperwork burden and economic effects on business: General Accounting Office→

Europe

Switzerland will continue to operate as a highly attractive business location despite global tax deal, finance ministry says: Reuters→

Austria

How will the European Commission define shell companies to stop tax avoidance?

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Americas

Perú tax authority considerations about the use of multi-year data in determining arm’s length transfer pricing

Zaida Limongi, TP Consulting Perú, discusses the Peruvian tax administration’s April 15 transfer pricing guidance . . .

Europe

Greece enacts corporate tax rate reduction, other support measures

Emmanouela Kolovetsiou-Baliafa, KG Law Firm, discusses a Greek law retroactively reducing the corporate income tax rate, suspending of the special solidarity contribution (SSC), and introducing other support measures that were published in the Official Gazette on May 18 . . .

Digital Economy

Ukraine passes ‘Google tax’ law impacting non-resident digital service providers

Iryna Kalnytska, GOLAW, discusses the Ukrainian parliament’s June 3 adoption of a bill introducing the so-called “Google tax,” which directly affects large non-resident companies that provide electronic and digital services in Ukraine . . .

Asia-Pacific

Australia budget includes tax changes affecting foreign investors

Paul McNab, Partner, DLA Piper, discusses Australia’s federal budget, delivered on May 11, which includes a number of tax measures relevant to foreign investors . . .

Accounting

Canada consults on tax issues under new insurance accounting rules

Canada’s Department of Finance on May 28 launched a consultation on the tax implications of new international accounting rules for insurance contracts . . .

OECD should rein in model treaty changes on transfer pricing of financial transactions, commentators say

The OECD’s business forum (BIAC) said in a May 28 comment letter that the OECD’s proposed changes to the OECD model tax convention commentary under article 9 relating to the interaction of transfer pricing . . .

Europe

Ireland’s new VAT rules for goods arriving into Ireland from non-EU countries enter into effect July 1, government notes: Irish Revenue→

Americas

UK finance minister says US plan to break global tax deadlock could work: William Schomberg / Reuters→

Americas

Cyprus to oppose global min tax, EU public country-by-country reporting: eKathimerini.com→

Americas

Biden floats corporate minimum tax in lieu of rate increase for bipartisan deal

June 3, 2021

To close a bipartisan infrastructure deal, President Biden suggested to a key Republican negotiator that he would consider forgoing his proposed corporate tax rate increase if Republicans would agree to a new . . .

Americas

US Senate Finance Committee Chair Wyden investigates AbbVie’s international tax practices

June 3, 2021

US Senate Finance Committee Chair Ron Wyden, D-Ore., on June 2 began an investigation into AbbVie’s international tax strategies and accused the biopharmaceutical company of . . .

Asia-Pacific

China cancels export VAT refund for iron and steel products

June 3, 2021

Grace Lin, Cuatrecasas, discusses Chinese government guidance, applicable May 1, on the export VAT refund for iron and steel products . . .

Asia-Pacific

Singapore declines to limit tax on imported low-value goods

The Inland Revenue Authority of Singapore (IRAS) on May 28 announced that it will not adopt several requested changes to the scope of the tax on imported low-value . . .

Asia-Pacific

Cormann takes over at OECD, says global tax deal likely

Mathias Cormann took office June 1 as the sixth Secretary-General of the OECD . . .

Americas

US plans tariffs against six nations as digital tax talks heat up

The US Trade Representative on June 2 announced and then immediately delayed implementation of new tariffs on goods from six countries – Austria, India, Italy, Spain, Turkey, and the UK – in response to . . .

Asia-Pacific

Australia updates and extends through year-end its guidance on whether a PE is created from the presence of employees in Australia due to COVID-19: Australian Taxation Office→

Europe

EU states should increase cooperation on corporate tax rates and base to reduce tax competition and avoidance irrespective of any global agreement, IMF paper concludes: International Monetary Fund→

Austria

EU reaches agreement on public country-by-country tax reporting

Negotiating teams from the European Council and European Parliament reached an agreement on June 1 on a proposed directive that would require public disclosure of country-by-country tax information by certain . . .

Asia-Pacific

Australia, UK agree on how to apply the arbitration provisions added via the MLI to their tax treaty: Australian Taxation Office→

Asia-Pacific

MLI’s changes to Singapore-Malaysia tax treaty took effect June 1, government notes: Inland Revenue of Singapore→

Asia-Pacific

Glencore prevails in the Cobar copper transfer pricing dispute, but should it have?

New York City Economist Dr. J. Harold McClure discusses Glencore’s transfer pricing dispute with the Australian Taxation Office and assesses whether the courts reached the correct conclusions. . .

Accounting

AICPA urges Congress to set tax preparer standards