Latest

The OECD has announced that Burkina Faso on October 30 deposited instruments . . .

Americas

Canada Revenue appeals long-running transfer pricing dispute loss to Supreme Court

The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss . . .

Europe

Ireland provides guidance on DAC6 reporting of cross-border arrangements: Irish Tax and Customs→

Americas

US IRS again corrects FDII and GILTI regs: Federal Register→

Americas

Peru to exchange tax information on companies and individuals with other nations

Yasser Zola, Transfer Pricing Manager at BaseFirma Peru, Lima, notes that according to an October 19 Peru tax authority announcement, Peru will soon begin exchanging tax information with other countries . . . .

Europe

Commission opinion asserts that Spain has missed deadline to transpose hybrid mismatch directive into law and threatens lawsuit unless action is taken within two months: European Commission→

Europe

Commission asks France to change taxation of foreign investment fund capital gains arising from sales of French company shares: EU Commission→

Europe

EU Commission refers Greece to Court of Justice over rules that provide different tax treatment for losses incurred domestically and those incurred in other EU/EEA state: EU Commission→

Europe

CJEU rules that EU freedom of establishment does not preclude application of Romanian transfer pricing law imputing market-rate interest on loan between parent and branch located in another state: Court of Justice of the European Union→

October 30, 2020

Asia-Pacific

Sri Lanka publishes new transfer pricing disclosure form and guide: Sri Lanka Inland Revenue→

October 30, 2020

Asia-Pacific

India retains transfer pricing tolerance range for 2019–20

October 30, 2020

Gaurav Jain, Chartered Accountant, and Priya Bhutani discuss an October 19 India Central Board of Direct Taxes announcement setting the transfer pricing tolerance range for 2019–20 . . .

OECD releases new methodology for peer review of country-by-country reporting minimum standard

The OECD today released a new methodology for judging whether 137 countries and their tax administrations have met minimum standards . . .

Asia-Pacific

Tax treaty between Georgia and Japan has been renegotiated

Gela Barshovi, International and Georgian tax adviser and managing partner at TPsolution, notes that Georgia and Japan competent authorities on October 22 announced that they renegotiated the current tax treaty between Georgian and Japan . . .

Americas

US IRS limits taxpayers’ ability to “telescope” results of MAP and APA negotiations into current tax year, requiring taxpayers to instead amend prior years’ returns: Internal Revenue Service→

Europe

Of 39 large EU banks, 31 operate in tax havens and 29 report large profits in countries where no employees are located, suggesting profit shifting, new report concludes: Elena Gaita & Linda Kunertova / Transparency International EU→

Multinational

New report discusses tax policy issues associated with virtual currencies: OECD→

Europe

Spanish draft budget proposes to limit large MNEs’ tax exemption for dividends and capital gains from subsidiaries, tax real estate investment trusts: Carlos E. Cue & Laura Delle Femmine / El Pais→

Europe

Ireland releases tax bill, announces plan to enact interest deduction limits from 2022

Warren Novis, BDO Ireland, Dublin, discusses Ireland’s Finance Bill 2020, released October 22, which includes several tax provisions affecting multinational enterprises and Ireland’s plans to enact EU-compliant interest deduction limitations . . .

Americas

Croatia to initiate tax treaty negotiations with the United States

Ksenija Cipek, Head of Tax Risk Analysis, Ministry of Finance, Tax Administration, Croatia, discusses the Republic of Croatia’s decision to initiate proceedings to conclude a tax convention with the United States. . . .

Americas

US corrects final FDII and GILTI regs: Federal Register→

Multinational

UN tax subcommittee PowerPoint shows plan for new handbook for policymakers on carbon tax: United Nations→

Denmark

Denmark courts reject tax authority’s formalistic transfer pricing approach

Susi Baerentzen, Ph.D., Copenhagen, analyzes a string of transfer pricing cases decided over the past two years by Denmark’s Supreme Court and high courts which have ruled against the tax administration’s formalistic approach, the most recent example being the July 2 Western High Court ruling in the ECCO shoe case . . .

Africa

Zambia proposes changes to transfer pricing documentation requirements

Joseph Jalasi and Mailesi Undi of Eric Silwamba, Jalasi, and Linyama Legal Practitioners, Lusaka, discuss the international tax proposals in Zambia’s 2021 budget, released on September 25 . . .

Europe

Professors analyze EU General Court decision in Apple, noting drawbacks of using state aid concept to counter MNE tax avoidance: Stephen Daly, Ruth Mason / SSRN→

Digital Economy

Author proposes international taxation regime for cross border cloud computing businesses: Alexander Weisser / UNIGE→

Americas

Final US regs address absorption of NOL carryovers, carrybacks and update rules on consolidated groups that include life insurance and other companies: Federal Register→

Africa

South Africa presidential commission recommends adoption of digital tax, tax on processed metals, R&D tax credit incentive: Businesstech→