Latest

Americas

US IRS large business and international unit adds compliance campaigns on Puerto Rico individual investors act, taxable asset transactions: Internal Revenue Service→

Asia-Pacific

Australia confirms that compliance resources will not be used to determine existence of PE in some instances where employees are present due to COVID-19: Australian Taxation Office→

Asia-Pacific

Tax ruling addresses whether use of a Singapore investment company’s foreign-sourced dividend income from a related foreign investment company to offset a non-trade related intercompany debt triggers remittance rules: Inland Revenue Service of Singapore→

Asia-Pacific

Israeli tax circular addresses intercompany recharges from stock-based compensation

Jacky Houlie of JH & Co. Law Office and Shlomo Hubscher, JH Consulting Ltd., Tel Aviv-Yafo, discuss a recently issued tax circular released by the Israeli tax authorities . . .

Africa

First Look: OECD consultation focuses on improving cross-border tax dispute resolution

February 1, 2021

The OECD today hosted a consultation meeting on a planned review of minimum standards, agreed to by OECD and G20 countries in 2015, that aim to improve cross-border tax dispute resolution for multinational . . .

Asia-Pacific

First Look: India’s Budget – A step towards clarity for foreign investor taxation

February 1, 2021

Mukesh Butani and Seema Kejriwal, of BMR Legal in Delhi, take a first look at the Indian government’s budget proposals for 2021–22, released today, focusing on several important proposals that affect international taxation . . .

Americas

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

Americas

US Democrat senators introduce bill applying GILTI on a per-country basis, eliminating companies’ ability to deduct 10 percent of their tangible assets before GILTI applies: Sen. Amy Klobuchar→

Asia-Pacific

Hong Kong laws granting profits tax concessions for insurance-related business and setting March 19 the law’s effective date were gazetted, government notes: Hong Kong government→

Americas

US, Argentina agree to exchange country-by-country reports on large multinationals

The US and Argentina have signed a competent authority agreement to exchange . . .

Americas

New Paraguay law extends withholding tax to digital services

Valeria Saavedra, Senior Associate, at Basefirma Venezuela, Caracas, discusses a new Paraguay law, effective January 1, which imposes income tax withholding on payments made to nonresidents that provide digital services . . .

Americas

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

Americas

COVID-19 and tax treaties: the updated OECD guidance

Parwin Dina, Lead Client Service Partner and Global Tax Leader at GTS (Global Tax Services) UAE, discusses the OECD’s updated guidance on COVID-19 and tax issues, issued January 21 . . .

Americas

In a call to German minister Scholz, new US Treasury secretary pledges active US participation in OECD international taxation effort “to forge a timely international accord”: US Department of Treasury→

Europe

EU should better monitor tax information exchange to ensure data quality, encourage states to put tax data to better use, plug gaps such as lack of reporting for cryptocurrencies. ECA says: European Court of Auditors→

Europe

Ireland updates DAC6 guidance to clarify filing procedure when a disclosure is subject to legal privilege: Irish Tax and Revenue→

Europe

EU blacklist does not properly identify tax havens, Parliament says

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses an European Parliament non-legislative resolution, issued January 18, criticizing the EU tax blacklist . . .

Americas

US seeks feedback on burdens of reporting foreign currency transactions: IRS / Federal Register→

Asia-Pacific

Cairn Energy threatens to seize Indian government assets overseas to enforce 1.2 billion tax arbitration award: Aditi Shah & Aftab Ahmed / Reuters→

January 26, 2021

Americas

Janet Yellen sworn in as US Treasury secretary

January 26, 2021

Janet Yellen was sworn in Tuesday as the 78th Treasury secretary in US history . . .

Americas

Mark Mazur confirmed as US assistant secretary for tax policy

Mark Mazur, director of the Urban-Brookings Tax Policy Center and a former US Treasury Department assistant secretary for tax policy in the Obama administration, is the Biden administration’s new . . .

Digital Economy

Amazon to increase fees of Spanish companies that use its platform in response to imposition of 3 percent DST: Reuters→

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

Americas

US IRS solicits comments on whether treaty-based return position disclosures are burdensome: Internal Revenue Service / Federal Register→

Europe

Ferragamo France’s transfer pricing dispute and resale price method abuse

Dr. J. Harold McClure, a New York City economist, notes that a recent transfer pricing case decided by France’s Supreme Administrative Court appears to involve a distribution affiliate with persistent operating losses despite purporting to use arm’s length margins, a pattern discussed in detail by Dr. Ednaldo Silva in his January 6 MNE Tax article . . .

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

Digital Economy

Italian digital services tax takes its first steps

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the Italian revenue agency’s January 15 release of final guidance on the national digital services tax, provision n. 13185/2021. . .

Asia-Pacific

Australian guidance addresses how investors holding hybrid securities on capital account determine market value when there is a buy-back or redemption: Australian Taxation Office→

January 22, 2021

Europe

Swedish court denies telecom giant’s tax deduction for exchange losses

Erik Koponen, Transfer Pricing Specialist at Thorning Koponen Consulting, Sweden, discusses a Swedish Lower Administrative Court decision issued on January 4 that upheld the Swedish tax agency’s denial of a deduction for losses related to a currency conversion of a loan . . .

Asia-Pacific

China should consider new tax on tech companies, securities regulation official and former vice finance minister say: Cheng Siwei, YU Hairong, Zhang Erchi, and Denise Jia / Nikkei Asia→

Africa

Rwanda introduces transfer pricing regulations

Rubeena Dina, Director at GTS Africa – Mauritius, discusses a Rwandan government ministerial order establishing general rules on transfer pricing . . .

Americas

US Treasury nominee Yellen would delay corporate rate increase because COVID recovery takes priority, would work with OECD to stop tax “race to the bottom”: Thomas Franck / CNBC→

Asia-Pacific

Vietnam’s transfer pricing regulations create new challenges

Tu Ha, Transfer Pricing Director at Duff & Phelps, Vietnam, discusses new Vietnam transfer pricing regulations, effective from December 20, 2020, that replace all former transfer pricing regulations . . .

Africa

Transfer pricing and the cumulative advertising effects on sales

Dr. Ednaldo Silva, founder and managing director of RoyaltyStat, Bethesda, Md., discusses the effect of advertising on enterprise-level sales, arguing that marketing intangible producing activities such as advertising expenses cannot coexist with the legal concept of limited function distributor or retailer . . .

Digital Economy

Ireland updates Corporate Tax Roadmap: Ireland Department of Finance →

Digital Economy

EU Commission to soon publish Communication on Business Taxation for the 21st Century, will propose digital levy mid-2021: Valdis Dombrovskis / European Commission→

Estonia

Estonia joins BEPS multilateral tax treaty

Estonia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty . .

Americas

US IRS publishes final PFIC regs (TD 9936): US Treasury / Federal Register→