Latest

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

Americas

US Treasury Secretary Yellen says tax moves needed to help tackle climate change

US Secretary of the Treasury Janet L. Yellen spoke on April 21 of the Biden administration’s “whole-of-government approach” to aggressively tackling climate change – including creating a targeted investment tax credit . . .

Americas

Google UK paid just £50 million (69.14 million USD) in corporate tax last year, despite posting £1.8 billion (2.49 billion USD) of revenues: Chris Newlands / inews→

Europe

Poland clarifies its unique definition of “controlled transaction” for transfer pricing purposes

Dr. Monika Laskowska, Center of Tax Analyses and Studies, discusses Poland’s early April launch of a public consultation on new transfer pricing guidance defining controlled transactions . . .

Asia-Pacific

Maldives publishes advance pricing arrangement regulations

Zaina Zahir, CTL Strategies, discusses the Maldives Inland Revenue Authority’s advance pricing arrangement regulations published on March 16 . . .

Americas

Brazil proposal would enhance tax incentives for technology R&D

Doris Canen, International Tax LLM, discusses a bill to extend the benefits of Brazil’s R&D tax incentive that is pending before the Commission for Economic Development, Industry, Commerce, and Service . . .

Asia-Pacific

Netflix Korea reports its 2020 financials: transfer pricing implications

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Netflix’s new 2020 financial reporting in South Korea . . .

Asia-Pacific

Australian tax guidance clarifies compliance with imported hybrid mismatch rules

The Australian Taxation Office issued draft guidance on April 21 regarding its assessment of compliance with the imported hybrid mismatch rules. The guidance is intended to help taxpayers prepare for compliance reviews. The imported hybrid mismatch rules aim to prevent taxpayers from entering

Europe

Ireland positions itself as counterpoint to US in debate over global minimum tax

Irish Finance Minister Paschal Donohoe today confirmed that Ireland would resist the push for a global minimum tax to the extent that it would infringe on the country’s 12.5 percent corporate tax rate . . .

Digital Economy

UN committee considers updates to model tax treaty, developing nation tax guidance

The UN Committee of Experts on International Cooperation in Tax Matters has released documents that reveal that significant changes are proposed for the United Nations Model Double Taxation Convention between Developed and Developing Countries and UN guidance addressing . . .

Accounting

FASB to host virtual credit loss panel

The Financial Accounting Standards Board (FASB) announced on April 20 that it will host a virtual roundtable next month on implementing the current . . .

Accounting

FASB appoints three members to small business advisory committee

The Financial Accounting Standards Board (FASB) on April 20 announced the appointment of three new members . . .

Digital Economy

OECD report looks at impact of digitalization of tax administrations in dealing with the COVID-19 crisis, assessing taxpayer services, compliance risk management, remote working, IT systems, support for wider government: OECD→

Asia-Pacific

Philippines updates procedures for claiming tax treaty benefits

John Regalado & Tanya Beatriz Y. Tan, SyCip Salazar Hernandez & Gatmaitan, discuss the Philippine government’s March 31 memorandum that streamlines the procedures for access to Philippine tax treaty benefits . . .

Belgium

ECJ to rule on whether DAC 6 tax reporting obligation infringes rights

A Belgian court has requested a preliminary ruling from the European Court of Justice with respect to whether certain fundamental EU rights are infringed by a provision of DAC 6, which requires mandatory automatic exchange of information in the field of taxation in

Europe

UK tables amendments to hybrid rules

The UK government, on April 15, tabled for the Committee of the Whole House amendments to Finance Bill 2021 relating to the corporate tax rules on hybrids and other mismatches . . .

Hong Kong proposes new rules enhancing deductibility of foreign tax

Stefano Mariani & Bernie Ng, Deacons, discuss Hong Kong’s gazetting of the Inland Revenue Bill 2021 on 19 March, seeking to expand and clarify the profits tax deductions for foreign taxes . . .

Americas

UN Committee of Experts approves new digital tax article for model treaty

The UN Committee of Experts on International Cooperation in Tax Matters today agreed to the text of a new article and commentary for the UN model tax treaty that would grant . . .

Asia-Pacific

China guidance addresses new tariff and tax incentives for integrated circuit, software industries

Grace Lin, Head of Tax, Cuatrecasas, Shanghai, discusses the Chinese government’s issuance in March of two notices clarifying tariff and tax incentives for the circuit and software industries . . .

Americas

Canada’s 2021 budget includes proposals on digital taxes, profit shifting, interest deductibility

Canada’s Budget 2021, presented by Finance Minister Chrystia Freeland on April 19, proposes several significant tax measures affecting multinational enterprises . . .

Digital Economy

Digital platforms should assist tax compliance efforts, OECD says

The digital platforms that have fueled the growth of the sharing and gig economies have a role to play in value-added tax (VAT) and goods and services tax (GST) compliance and administration, the OECD said . . .

More News

Democrat bill aimed at fossil fuel industry would eliminate tax credits and subsidies, restrict deductions: Senator Edward J. Markey→

Americas

IRS asks for public input on priorities for tax guidance

The IRS has released an advance version of Notice 2021-28 that invites recommendations for items to be included in the 2021-2022– Priority Guidance Plan. The 2021–2022 Priority Guidance Plan will identify tax guidance projects that the Treasury Department and the IRS intend to

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Europe

OECD names new chair of international tax policy body

The OECD announced on April 16 that it appointed Fabrizia Lapecorella as the new head of the Committee on Fiscal Affairs starting on January 1, 2022. . .

Africa

Switzerland, Luxembourg do not appear on tax blacklists while island nations do, creating the perception of racial bias, professors say: Steven A. Dean & Attiya Waris / SSRN→

More News

International Compliance Assurance Programme (ICAP) FAQs provided: OECD Forum on Tax Administration→

April 18, 2021

Americas

JCT provides overview of US tax system: Joint Committee on Taxation →

April 16, 2021

Americas

US proposes rules for foreign persons investing in qualified opportunity funds

The IRS published proposed rules on April 14 setting forth requirements that certain foreign persons and foreign-owned partnerships would have to meet to elect the tax benefits related to investing in qualified opportunity funds. . .

Denmark

Danish Ministry of Taxation admits defeat in important transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Ministry of Taxation’s March 25 announcement that it was withdrawing its challenge in a 2018 transfer pricing dispute . . .

Americas

IRS warns taxpayers on microcaptive insurance arrangements

Participants involved in abusive microcaptive insurance arrangements should exit the transactions now and not attempt to claim associated deductions on their 2020 tax returns, the IRS said in an April 9 statement. . .

Americas

Avery Dennison wins Chile transfer pricing dispute over intercompany loans, distributor margin

Dr. J. Harold McClure, New York City, discusses the multinational manufacturer Avery Dennison Corporation’s March 31 win in its transfer pricing dispute with the Chilean tax authority. . .

Asia-Pacific

Google Korea, Facebook Korea report income for the first time but in questionable sum: Hong Sung-yong & Minu Kim / Pulse→

Americas

US confident “vast majority” of developed nations will approve global minimum tax, US deputy treasury secretary says: Thomas Franck / CNBC→

Americas

Wyden says Treasury’s OECD proposal would address digital taxes that discriminate against US companies while supporting US tax reform goals: US Senate Committee on Finance→

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

Americas

NGO proposal revises minimum tax to overcome OECD approach’s shortcomings

The proponents of a new minimum effective tax rate proposal for multinational corporations say their proposal would modify the OECD’s proposed global anti-base erosion tax (GloBE) . . .

Americas

US support for R&D has stalled relative to France, UK, others