Latest

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Americas

Countries should suspend their DSTs now to show they are serious about reaching global agreement on international tax, ranking member says: US Senate Finance Committee→

Multinational

The case for a sustainable excess profits tax using life cycle analysis methods: Allison Christians and Tarcisio Diniz Magalhaes / SSRN→

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

Africa

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Europe

Spanish finance minister says Spain favors global minimum corporate tax, presents committee with broad tax reforms to bolster revenue: Explica.co→

Asia-Pacific

Turkey considers raising corporate income tax rate to 25% for 2021, then reducing to 23%: bne IntelIiNews→

Americas

Canada’s Manitoba budget changes e-commerce taxation in December 2021: Manitoba government→

Americas

India unlikely to agree to global minimum tax: Arup Roychoudhury / Moneycontrol→

April 9, 2021

Americas

Cyprus divided on Yellen’s minimum corporate tax: Andrew Rosenbaum / CyprusMail→

April 9, 2021

Asia-Pacific

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

April 9, 2021

Asia-Pacific

Australian court holds R&D tax offset refund was paid by mistake, subject to recovery provision

April 8, 2021

The Federal Court of Australia held on March 19 that a research & development tax offset refund claimed by, and paid to, a taxpayer, but to which the taxpayer was not entitled, is subject to . . .

Africa

US offers new “Pillar One” compromise plan for taxing large multinationals

April 8, 2021

The Biden administration has proposed a new “Pillar One” scheme for taxing multinational groups to a coalition of 139 countries . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Americas

Biden fleshes out international tax plan, Senate Democrats offer their take

A US Treasury Department report released on April 7 expands on the corporate tax plan announced by the Biden Administration last week . . .

Americas

Ireland may not agree to global minimum tax, minister says

There may not be agreement among all G20 nations on a global minimum corporate tax, according to Ireland’s Finance Minister and Eurogroup President Paschal Donohoe, who . . .

Africa

UN tax committee releases updated model treaty language on automated digital services

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters today released its final draft of proposed Article 12B and commentary on income from automated digital . . .

Europe

G20 ministers renew call for consensus over MNE taxation

G20 finance ministers and central bank governors on April 7 renewed their call on for agreement on new tax rules for multinational groups. . .

Digital Economy

OECD Secretary-General report to G20 ministers includes overview of 66 countries’ tax policy responses to COVID-19: OECD→

Multinational

Professor analyzes OECD model treaty changes regarding entitlement to tax treaty benefits for income received through transparent entities: Leopoldo Parada / SSRN→

Europe

Luxembourg tax guidance addresses new interest limitation rule

Sophie Richard and Adnand Sulejmani, Arendt & Medernach S.A., discuss Luxembourg guidance on the application of a new interest limitation rule, implemented in a new Article 168bis of the income tax law. . .

Asia-Pacific

China enhances R&D super deduction for manufacturing, extends multiple tax breaks for doing business in China

Hengka (Henry) JI, Zhong Lun Law Firm, discusses the March 15 release by China’s Ministry of Finance and State Administration of Taxation of “Announcement No. 6 of 2021 Concerning the Extension of Several Preferential Tax Policies”. . .

Americas

US West Virginia Democratic Senator Manchin says he won’t support Biden’s proposed 28% corporate tax hike, that 25% is more appropriate: Alexander Bolton / The Hill→

Antigua and Barbuda

Countries continue to permit tax treaty shopping despite BEPS promises

Most countries are not fulfilling their commitment to amend their tax treaties to meet global standards aimed at preventing tax avoidance through tax treaty shopping, an April 1 OECD report shows. . .

International Monetary Fund

Countries should consider temporary tax on “excess” corporate profits to lessen inequality resulting from Covid-19 pandemic, IMF says: International Monetary Fund→

Americas

US Treasury Secretary Yellen calls for G20 agreement on global minimum tax

US Secretary of the Treasury Janet Yellen said on April 5 that she is working to get buy-in from G20 nations on a global minimum corporate tax . . .

Americas

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

Europe

Peru tax authority addresses appropriate method for intra-group services under prior law

Carlos Vargas Alencastre of TPC Group, Peru, discusses the Peruvian tax administration’s March 18 guidance clarifying the transfer pricing rules applicable to intragroup services. . .

Multinational

NGOs ask public for new ideas on ways resource-rich developing countries can maximize tax revenues from mining: Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development→

Europe

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

Europe

Russia, Luxembourg ratify protocol increasing withholding tax rates for dividends and interest income to 15 percent: Tass→

Europe

Ireland updates guidance on capital allowances for intangible assets

Irish Revenue updated its tax manual guidance on capital allowances for intangible assets on March 31 to reflect amendments made by Finance Act 2020. . .

Asia-Pacific

Singapore updates guidance on business foreign exchange gains or losses: Inland Revenue of Singapore→

Asia-Pacific

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

Asia-Pacific

China simplifies unilateral advance pricing arrangement procedures for some taxpayers

Agnes Lo, Lingnan University, and Raymond Wong, City University of Hong Kong, discuss China’s State Taxation Administration’s March 19 guidance simplifying unilateral advance pricing arrangement procedures for some taxpayers. . .

Americas

Biden’s corporate tax plan would increase rates, upend international provisions

President Biden’s corporate tax plan released on March 31 would raise the US corporate tax rate to 28%, increase the global minimum tax and calculate it on a country-by-country basis. . .

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Americas

US business group urges Congress to pass bill preserving companies’ ability to immediately deduct R&D expenses: US Chamber of Commerce→

Proposed OECD model tax treaty updates cover transfer pricing for interest payments, corresponding adjustments