Latest

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

United States

US IRS releases 2020-21 priority tax guidance plan: US Department of Treasury→

Americas

Carol Doran Klein retires from USCIB, Rick Minor takes over as tax lead: USCIB→

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Transfer Pricing

UAE launches country-by-country reporting platform: Gulf News→

Americas

US should amend tax rules providing that foreign funds that originate loans have effectively connected income because the policy if flawed and funds work around the rule anyhow, attorney argues: David S. Miller / Proskauer Rose LLP→

Asia-Pacific

China signed 21 advance pricing arrangements in 2019, report shows

Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong, and Raymond Wong, Associate Professor, City University of Hong Kong, discuss an October 29 report issued by China’s State Taxation Administration that provides statistics on China’s advance pricing arrangement program through 2019 . . .

Africa

South Africa considers advance pricing agreement program

The South African Revenue Service on November 11 published a discussion paper seeking public feedback . . .

Europe

EU plans to revise energy taxation by next summer to promote reduced emissions, head of climate policy says: Kate Abnett / Reuters→

Americas

First Look: US and Mexico renew of competent authority agreement on Maquiladoras

The US IRS on November 16 announced that the US and Mexico have . . .

Europe

UK report evaluating research and development credit concludes that while the tax credit cost £2.4bn in 2017-18, it may have stimulated £5.8–£6.5bn of additional corporate spending: Georgia Scott & Tim Glinert / HM Revenue & Customs→

Europe

UK report evaluating patent box finds a 10 percent increase in investment by companies that using the tax incentive versus those that do not: Max Rowe-Brown & Huw James /HM Revenue & Customs→

Americas

US IRS again corrects final regs (TD 9909) limiting deduction for dividends from foreign corporations: Federal Register→

Americas

US IRS invites the public to recommend guidance that should be rescinded, modified, or waived to assist businesses and individuals recover from economic effects of COVID-19 pandemic: Federal Register→

Africa

Zambia’s transfer pricing advances and the Mopani copper mine dispute

Dr. J. Harold McClure, New York City, discusses a November 12 OECD case study on Zambia’s landmark Supreme Court victory in a transfer pricing dispute involving the Mopani copper mines and notes transfer pricing issues addressed and not addressed in the Court’s decision . . .

Americas

Chip Harter, US Treasury deputy assistant secretary for international tax affairs, to leave his post this month: Bernie Becker / POLITICO→

Europe

Malta releases DAC6 XML Schema and user guide for reporting cross-border arrangements: Office of the Commissioner of Revenue→

Americas

US IRS corrects final regs limiting deduction for dividends from foreign corporations: Federal Register→

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

Africa

East African nations pledge to jointly address taxation of digital firms

Tax officials from Kenya, Uganda, Tanzania, Rwanda, South Sudan . . .

Africa

South Africa extends deadlines to file country-by-country reports: South African Revenue Service→

Europe

UK draft tax proposals include hybrid mismatch fixes, R&D tax credit cap

The UK government today proposed additional tax legislation for Finance Bill 2021 . . .

Europe

Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties

Switzerland’s Federal Council, at its November 11 meeting, approved . . .

Asia-Pacific

Malaysia provides English-language translation of guidance outlining procedure for appealing tax assessments: Inland Revenue Board of Malaysia→

Digital Economy

Nations must agree to tax regime for digital firms that produces “a fair tax system that provides long-term sustainable revenues” or the EU will make its own proposal, von der Leyen says: European Commission→

Europe

Guernsey extends country-by-country reporting filing deadlines for constituent entities because of COVID-19: States of Guernsey→