Latest

Europe

Ireland updates guidance on DAC6 mandatory disclosure regime: Irish Tax and Customs→

Asia-Pacific

Energy giant Cairn wins Rs 8,000 crore (USD 1.2 billion) arbitration award in dispute with India over taxation of indirect transfer of assets: Dilasha Seth / Business Standard→

Americas

US Congress passes stimulus bill that extends PTC and ITC for land-based wind for one year at 60%, solar ITC for two years at 26%, gives offshore wind projects a 30% ITC, extends tax credit for carbon recapture by two years: Catherine Morehouse / Utility Dive→

Europe

Updated Ireland R&D tax credit guidance addresses plant and machinery, reflects UK’s withdrawal from EU: Irish Tax and Customs→

December 22, 2020

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Practical obstacles prevent low-income countries from participating in global tax standard-setting through Inclusive Framework, authors say: Rasmus Corlin Christensen, Martin Hearson, & Tovony Randriamanalina / The International Centre for Tax and Development→

Americas

Mexican proposal to block foreign digital services providers if they fail to comply with digital tax rules could violate USMCA: Inu Manak & Alfredo Carrillo Obregon / Cato At Liberty→

Asia-Pacific

Germany and Pakistan deposit instruments of ratification for BEPS MLI with the OECD, joining 57 other countries; entry into force is April 1, 2021, for both countries: OECD→

Americas

Peru tax authority requires multinational groups to file country-by-country reports

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses Peru tax authority guidance, published on December 2 and December 16, addressing multinational groups’ obligation to file country-by-country reports . . .

Africa

Benin introduces transfer pricing private ruling procedure

Moïse Gnakouri, a Doctoral researcher at the Catholic University of Louvain, Brussels, Belgium, discusses a new law adopted by the Benin parliament on December 8 that allows multinationals to apply for transfer pricing rulings . . .

Americas

Cayman Islands amends country-by-country reporting guidance and schema

The Cayman Islands on December 17 issued amended country-by-country reporting . . .

First Look: OECD guidance examines transfer pricing issues created by the COVID-19 pandemic

December 18, 2020

Today, the OECD published guidance on transfer pricing issues that arise or may be exacerbated on . . .

Europe

Ireland provides guidance for taxpayers seeking to rely on private tax rulings issued in 2015 for periods after January 1, 2020: Irish Tax and Customs→

December 17, 2020

Asia-Pacific

Australia updates transfer pricing guidance on simplified record-keeping options: Australian Taxation Office→

December 17, 2020

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

The OECD today released more than 250 comment letters in response to a request for public . . .

Europe

Ireland tax office outlines procedure and operation of co-operative compliance framework for large corporates: Tax and Duty Manual→

Europe

German transfer pricing guidance addresses taxpayers’ obligation to cooperate with tax office

Konstantin Sakuth of Linklaters LLP, Munich, discusses December 3 transfer pricing guidance issued by Germany’s Federal Ministry of Finance that addresses a multinational group taxpayer’s obligation to cooperate with the tax authorities concerning income allocation . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Asia-Pacific

China official says governments should consider levying digital taxes on online platforms because users created the value and should share in the profits: Reuters→

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

Americas

Taxing multinational group excess profit in the US, UK, and Belgium

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Asia-Pacific

Japan, Switzerland to negotiate tax treaty amendments

Japan’s Ministry of Finance today announced that the government of Japan and the Swiss . . .

Africa

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

Americas

Canada’s bolder stance on unilateral digital taxes likely prompted by reduced fear of tariffs in Biden administration: Andy Blatchford / Politico→

Europe

UK seeks feedback on proposed VAT changes that reflect digital platform “sharing economy”

The UK’s HM Treasury has requested public feedback on whether the VAT rules should be changed . . .

Americas

US Senate follows House in passing law requiring existing and future US companies and LLCs to disclose information about beneficial owners: Jeanne Whalen / The Washington Post→

Asia-Pacific

Singapore updates guidance on law providing for nontaxation of gain on disposal of equity investments through 2027: Inland Revenue Authority of Singapore→

Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

Europe

Blackrock’s transfer pricing battle with the UK: unexplored intercompany financing issues

Dr. J. Harold McClure, a New York City economist, discusses intercompany loan pricing issues revealed in a November 3 UK Tribunal decision favoring the UK affiliate of investment management group, Blackrock . . .

Americas

First Look: US releases final regs on source of income from sales of personal property

The US IRS on December 11 published final regulations (TD 9921) on the source of income from sales of inventory . . .

Americas

US makes additional corrections to regs (TD 9902) on income subject to a high rate of foreign tax: Federal Register→

Americas

US IRS corrects final regs (TD 9902) on income subject to a high rate of tax: Federal Register→

Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→