Latest

Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics, discusses new Polish guidance on disclosures required by taxpayers that conduct business with tax haven entities. . .

Americas

US IRS shortened completion time for advance pricing agreements in 2020 but backlog remains

The US IRS cut the median time to complete advance pricing agreements (APAs) down to 32.7 months in 2020, a drop of over six months from last year, its best completion time in five years, IRS statistics published on March 30 reveal. . .

Europe

Ireland updates and expands tax guidance on anti-hybrid rules

Irish Revenue updated the anti-hybrid provisions in its tax manual on March 29 to reflect amendments made by Finance Act 2020 with respect to how the anti-hybrid rules apply to a worldwide system of taxation. . .

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance

Greece and Hungary have deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), the OECD announced March 30. . .

Digital Economy

New Italian guidance addresses digital service tax details

Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan, discuss the Italian Revenue Agency’s long-awaited guidance issued on March 23 clarifying the application and implementation of the digital service tax. . .

Asia-Pacific

Taiwan advises sellers of digital goods and services to apply for tax registration

Individuals who use online platforms or social media software to sell goods or services for profit must apply for tax registration. Taiwan’s National Taxation Bureau of Kaohsiung, Ministry of Finance, said on March 26. . .

Digital Economy

EU Parliament committee adopts resolution on digital taxation

The European Parliament’s Committee on Economic and Monetary Affairs (ECON) on March 23 adopted a motion for a European Parliament resolution on digital taxation, OECD negotiations, tax residency of digital companies, and a possible European digital tax. . .

Americas

IRS releases agent training materials on interest and dividends received from CFCs: Internal Revenue Service→

South Africa High Court rules on its power to review tax authority actions

Prenisha Govender of Baker McKenzie, Johannesburg, discusses a March 11 High Court of South Africa judgment that addresses access to the courts in tax disputes . . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Transfer Pricing

States show renewed interest in transfer pricing agreements: JDSupra→

Europe

German cabinet adopts bill closing MNE tax avoidance loopholes

Germany’s federal cabinet on March 24 adopted a bill implementing the EU’s Anti-Tax Avoidance Directive, including stricter rules to fight aggressive tax avoidance strategies used by multinational corporations. . .

Americas

US Senate hearing foreshadows future legislative battles over international tax

US Senate Finance Committee members and speakers at a March 25 hearing advocated in favor of reforming the international tax system to better address multinational group profit shifting, debated raising the corporate tax rate, and found some agreement on the need to reform the base erosion and anti-abuse tax. . .

Americas

Canada’s Supreme Court rules federal carbon tax is constitutional: John Paul Tasker / CBC News→

Asia-Pacific

China to increase extra tax deduction for R&D expenses of manufacturing firms: State Council→

Americas

13 trade associations object to India’s proposed equalisation levy expansion

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

Africa

OECD details 30 countries’ approach to cross-border tax dispute arbitration

March 25, 2021

The OECD today added information to its website on 30 countries’ processes for arbitrating cross-border tax . . .

Europe

UK consults on aligning transfer pricing documentation requirements with OECD approach

The UK HM Revenue and Customs is considering potential new transfer pricing documentation requirements that would require businesses to prepare and provide specific documentation to support their transfer pricing . . .

Asia-Pacific

New Zealand parliament passes tax bill

The New Zealand government today announced that parliament has passed a tax bill that includes measures allowing businesses to claim greater deductions for feasibility expenditures . . .

Americas

US IRS releases agent instruction manual on the Section 965 transition tax on untaxed earnings of foreign corporations: Internal Revenue Service→

Europe

Ireland MEP says Parliament proposal to dispense with majority voting on tax issues that “distort” the single market skirt the treaty: Sarah Collins / Independent.ie→

Europe

Netherlands legislative proposal tackles transfer pricing mismatches

Jian-Cheng Ku and Tim Mulder, of DLA Piper Netherlands N.V., discuss the Dutch government’s publication on March 4 of its legislative proposal to tackle double non-taxation resulting from transfer pricing mismatches. . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Asia-Pacific

Singapore adopts BEPS-compliant IP tax incentives

Edmund Leow SC of Dentons Rodyk & Davidson LLP, Singapore, discusses Singapore regulations on its new concessionary income tax rules for intellectual property, which came into effect on January 22. . .

Greek transfer pricing guidance addresses the COVID-19 pandemic

Emmanouela Kolovetsiou-Baliafa of KG Law Firm, Athens, Greece, discusses a Greek Independent Authority for Public Revenues circular providing guidance on the transfer pricing implications of the COVID-19 pandemic. . .

Europe

EU approves DAC 7 rules on digital platform tax reporting, joint audits

As expected, the EU Council on March 22 approved DAC 7, establishing new EU-wide rules that require digital platforms . . .

Asia-Pacific

India appeals Cairn Energy USD 1.4 billion arbitration award: The Economic Times→

Asia-Pacific

Mongolia’s first transfer pricing assessment – what could be the issues?

Dr. J. Harold McClure, New York economist, discusses the issues surrounding Mongolia’s first transfer pricing assessment. . .

Asia-Pacific

India’s lower house passes Finance Bill, 2021: Hindustantimes→

Asia-Pacific

Georgia amends transfer pricing rules for APAs, reduces thresholds

Gela Barshovi of TPsolution, Tbilisi, Georgia, discusses March 2 Georgia Ministry of Finance guidance amending the transfer pricing rules concerning the unilateral advance pricing agreement procedure . . .

Europe

EU sues UK for failure to recover Gibraltar tax benefits from multinationals

The European Commission reported on March 19 that it is referring the UK to the Court of Justice of the European Union for failing to comply with the Commission’s decision requiring it to recover €100 million of illegal state aid in Gibraltar. . .

Asia-Pacific

Bahrain introduces country-by-country reporting requirements