Latest

Certain foreign businesses earning income from cross-border electronic services sold to individuals in the Republic of China (Taiwan) must file income tax returns for 2020 through the online “eTax Portal” . . .

Digital Economy

OECD preparing plan to stop unilateral tax measures, Saint-Amans says

The OECD is working on a framework to prevent countries from enacting unilateral tax measures, such as digital services taxes, as part of an agreement under the “Pillar One” negotiations . . .

Asia-Pacific

How prudent is it to conduct transfer pricing risk adjustments for captive cost centres?

Smarak Swain, New Delhi, discusses India’s Income Tax Appellate Tribunal’s recent decision in a transfer pricing dispute, GCO Technologies Centre Pvt Ltd, focusing on whether adjustments should have been made to the comparables to reflect the captive service provider’s risk levels. . .

UN declines to amend model tax treaty on software payment taxation

The UN Committee of Experts on International Cooperation in Tax Matters, at its 22nd session, decided against adding a proposal to add computer software payments to the UN model tax treaty’s definition of royalty payments . . .

Africa

OECD’s Global Forum to train African tax officials

The OECD’s Global Forum launched in April its “Train the Trainer” pilot program – a move to provide local training to African tax auditors and investigators . . .

More News

US senators query whether former attorney general Barr stalled Caterpillar tax investigation

US Senate Finance Committee Chair Ron Wyden, D-Ore., and Senator Sheldon Whitehouse, D-R.I., launched an investigation on April 28 into whether Trump administration interference stalled a tax investigation of Caterpillar . . .

Accounting

New US tax schedules allow enhanced international tax reporting for pass-throughs

The US Treasury Department and the IRS, on April 30, released early release drafts of redesigned schedules K-2 and K-3 for forms 1065, 1120-S, and 8865 for tax year 2021 . . .

Asia-Pacific

Global minimum tax opponents will not stop agreement, Saint-Amans says

Negotiations on a global minimum tax on corporations have the momentum that they need to reach an agreement now that France, Germany, and others have signaled support for recent US proposals. . .

Asia-Pacific

New Singapore transfer pricing guide addresses MNE centralised services

Adriana Calderon, Transfer Pricing Solutions Asia Pte Ltd, discusses the Inland Revenue Authority of Singapore’s release on March 19 of transfer pricing guidelines on centralized services . . .
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Europe

Singapore and Serbia sign income tax treaty

Singapore and Serbia have signed an income tax treaty, Singapore’s Inland Revenue Authority announced on May 3 . . .

Digital Economy

UN versus OECD – It’s time for the UN to get going

Kuldeep Sharma, ADIT (CIOT, UK), discusses why it’s time for the UN to come out of the shadows of the OECD, make structural changes to its tax committee and strengthen its Secretariat to bring it at par with the OECD . . .

Multinational

OECD and francophone tax administration group CREDAF renew agreement to promote fair tax systems: OECD→

Americas

Switzerland rejects Biden’s tax haven claim: swissinfo.ch→

Americas

Bermuda leaders chafe at Biden’s tax haven label: Scott Neill / The Royal Gazette→

Europe

Ireland amends R&D tax credit guidance to address rental costs

An updated version of Irish Revenue’s tax guidance on the research and development (R&D) tax credit, released April 28, adds a section on rent as a qualifying expenditure for R&D activities, among a few other revisions.

Accounting

FASB council considers cash flow statement, financial performance reporting changes

Members of the Financial Accounting Standards Advisory Council (FASAC) expressed support for certain improvements to cash flow statements in an April 8 meeting in which they discussed the importance for FASB to improve various financial reporting areas . . .

Asia-Pacific

New Zealand enhances R&D tax credit refundability to lessen impact of COVID-19

New Zealand’s Inland Revenue has brought forward by one year the application date of broader refundability for the R&D tax credit in a move intended to help businesses retain their R&D capability during the COVID-19 outbreak, the government said . . .

Americas

British Virgin Islands extends deadlines for CbCR, CRS, and FATCA reporting due to technical difficulties: Virgin Islands National Tax Authority→

Multinational

Tax Inspectors Without Borders has helped developing countries bring in more than USD 1 billion in additional tax revenues: OECD→

Americas

Biden plan would raise US MNE taxes by 81 percent, create incentives for profit shifting out of the US, think tank concludes: Cody Kallen / Tax Foundation→

Denmark

Denmark Supreme Court rules in Tetra Pak transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Supreme Court’s April 26 ruling in a landmark transfer pricing case involving a Danish company Tetra Pak that produced and sold plants for manufacturing ice cream . . .

Europe

Switzerland fears impact of minimum corporate tax rate: Matthew Allen / Swissinfo.ch→

Americas

Biden’s American Families Plan proposes additional IRS funds to scrutinize large corporation taxes: The White House→

Europe

Ireland updates dividend withholding tax guidance to reflect Finance Act 2020 changes: Irish Revenue→

Africa

UN updates transfer pricing manual for developing countries

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

GOP infrastructure counterproposal would seek to avoid corporate and international tax hikes through smaller plan and reallocated spending: Minority, US Senate Committee on Environment and Public Works→

Digital Economy

US state of Connecticut considers digital advertising tax with international implications similar to state of Maryland’s: Connecticut General Assembly →

Americas

Wyden touts plan to replace “hodgepodge” of oil and gas tax incentives with clean energy producer breaks: United States Senate Committee on Finance→

Europe

Hungary says global minimum tax would violate sovereignty, refuses to consent: Budapest Times→

Americas

French and German finance ministers voice support for US proposal on global minimum tax: Reuters→

Americas

Google UK reports its 2020 financials: the transfer pricing implications

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Europe

EU preferential regimes and Code of Conduct Group: state of play

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses several developments in April regarding the EU Code of Conduct Group’s effort to rein in tax avoidance . . .

Americas

Brazil’s Supreme Court addresses software taxation

Francisco Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados and Rachel Mira Lagos, Bocater Advogados, discuss a important Brazilian Federal Supreme Court ruling on software taxation . . .

Europe

Spanish guidance clarifies transfer pricing arm’s length range

Mario Ortega and Íñigo García, J&A Garrigues, S.L.P., discuss Spain’s February 24 transfer pricing guidance on arm’s length price . . .

Americas

Mexico amends tax rules on outsourcing, insourcing services