Latest

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a new Italian law related to advance pricing agreements . . .

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Africa

South Africa invites public comment on advance tax ruling process: South Africa Revenue Service→

Americas

Day 2 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

Americas

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

Americas

OECD adds transfer pricing country profiles for Argentina, Dominican Republic: OECD→

January 15, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Digital Economy

EU seeks public input to design of digital levy

January 14, 2021

The EU Commission today requested feedback on the design of its coming . . .

Asia-Pacific

Final Australia targeted integrity rule addresses hybrid mismatches: Australian Taxation Office→

January 14, 2021

Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Council of the EU

EU agenda includes public country-by-country reporting

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the Portuguese Presidency of the Council of the European Union’s January 1 announcement of its priority program, including tax policy priorities . . .

Europe

Swedish tax agency clarifies DAC6 transfer pricing hallmarks

Emilia Ferrão, a Transfer pricing specialist at Thorning Koponen Consulting in Stockholm, Sweden, discusses Swedish tax agency guidance issued in November and December 2020 that clarifies Sweden’s position on DAC6 “hallmarks” that trigger reporting related to transfer pricing . . .

Americas

Dow Chemical and Canada’s transfer pricing dispute: litigating pennies while ignoring a large toll manufacturing issue

Dr. J. Harold McClure, a New York City economist, discusses the Tax Court of Canada’s December 18 decision in the Dow Chemical transfer pricing case, noting that the parties did not address a potential toll manufacturing issue . . .

Africa

From January 1, Kenya increases corporate rate to 30%, sets min tax at 1% gross turnover: Kenya Revenue Authority→

Bahrain

Bahrain clarifies VAT place of supply for telecommunication services: National Bureau for Revenue→

Europe

UK opens multiple criminal fraud probes following MNE tax avoidance investigations, HMRC officials confirm

The UK’s HM Revenue and Customs has opened “multiple” criminal fraud investigations stemming from investigations . . .

Europe

Norway’s oil lobby sharply criticizes plans to more than triple CO2 tax: Nora Buli & Nerijus Adomaitis / Reuters→

Africa

Kenya expects 100 nonresident businesses to register by this week to pay 1.5 percent tax on goods and services sold online, anticipates 900 others will join: John Mutha / Business Daily→

January 11, 2021

Americas

BVI notice addresses country-by-country reporting schema update and deadlines: Virgin Islands International Tax Authority→

January 11, 2021

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Americas

The origins of transfer pricing’s comparable profits method

Ednaldo Silva, Director, RoyaltyStat, Bethesda, Md., discusses the reasons why US IRS transfer pricing officials adopted the comparable profits method . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Europe

Italy unlocks tax dispute resolution mechanism

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 16 Italian tax guidance clarifying changes to Italy’s tax dispute resolution mechanism . . .

Digital Economy

Italian digital services tax is knocking at the door

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 17 guidance issued by the Italian tax authority that addresses Italy’s new digital service tax . .

Americas

Barbados deposits its instrument of ratification for the Multilateral BEPS Convention becoming the 60th to join: OECD→

Europe

Dutch informal capital scheme should be investigated for illegal state aid, professor says: Jan Vleggeert / SSRN→

Americas

EU Parliament’s plan for new tax blacklist would hit Cayman Islands: Cayman News Service→

Digital Economy

French High Court in Valueclick interprets tax treaty permanent establishment rules

Mickael Duquenne, Senior Manager and Pascal Luquet, Partner, at Grant Thornton Société d’Avocats, Paris, discuss a December 11 landmark decision of France’s Supreme Administrative Court concluding that an Irish company had a permanent establishment in France . . .

Americas

US IRS issues agent guide on qualified dividends and capital gains rate differential adjustments: Internal Revenue Service→

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

Europe

Facebook to wind up Irish divisions holding IP in response to tax law change: Julia Kollewe / The Guardian→

Europe

Malta issues guidelines on DAC 6 disclosures of crossborder arrangements: Office of the Commissioner for Revenue→

Asia-Pacific

Singapore ruling concludes that corporation and three foreign shareholders are not related parties for transfer pricing purposes: Inland Revenue Authority of Singapore→

Asia-Pacific

Taiwan offers foreign businesses advance rulings on tax liability

Taiwan’s tax authority on January 4 announced that foreign businesses that do not have a . . .

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Americas

Washington State legislators may soon debate digital advertising tax: Eversheds Sutherland SALT→

Asia-Pacific

Hong Kong, Serbia tax agreement enters into force

A comprehensive agreement providing for the avoidance of double taxation entered into force between Hong Kong . . .

Americas

The end of the “double-Irish” tax structure means that a greater share of MNE profits are taxed in the US where the R&D generating the profits is undertaken: Seamus Coffey / Irish Examiner→