Latest

Americas

Cayman Islands to propose changes to pending LLP law to improve its “commercial functionality” prior to the regime becoming operational: Cayman Finance→

Digital Economy

Facebook’s cryptocurrency, Libra, presents tax policy challenges, authors note: Allison Christians & Mahwish Tazeem→

Asia-Pacific

Synthesized text of Australia–Russia tax treaty, as modified by the MLI published: Australian Taxation Office→

Asia-Pacific

Synthesized text of Australia–Korea tax treaty, as modified by the MLI published: Australian Taxation Office→

Asia-Pacific

Synthesized text of Australia–Czech Republic tax treaty, as modified by the MLI published: Australian Taxation Office→

Asia-Pacific

Turkish government working on plan to reduce corporate tax rate to 15–18 percent beginning next year, official say: Daily Sabah→

Europe

EU Advocate General concludes that Poland’s retail tax and Hungary’s advertising tax, both based on turnover, are not State aid even though they primarily affect larger undertakings: Court of Justice of the European Union→

Asia-Pacific

Australia practice statement addresses interpretation of principal or main purpose tests in tax treaties: Australian Taxation Office→

Asia-Pacific

Japan, Georgia commence tax treaty negotiations: Japan Ministry of Finance→

Asia-Pacific

Georgia offers new tax incentives for foreign IT and shipping companies

Gela Barshovi, international and Georgian tax adviser and managing partner at TPsolution, Tbilisi, Georgia, discusses an October 8 Georgia’s government decree providing new tax incentives for foreign and Georgian companies involved in shipping and information technology . . .

Americas

Colombia publishes MAP guidance for resolution of tax treaty disputes

Juana Obando, Transfer Pricing Associate at BaseFirma Colombia, discusses August 21 Colombian tax authority guidance on the procedure to request the resolution of cross-border tax disputes under Colombia’s tax treaties . . .

Americas

France reinstates digital tax, courting trade war: Bjarke Smith-Meyer & Elisa Braun / POLITICO→

October 14, 2020

Digital Economy

G20 ministers vow to continue work on international tax rewrite

October 14, 2020

In a communique released after their October 14 virtual meeting, G20 finance ministers and central bank governors said they remain committed to achieving consensus . . .

Africa

OECD Pillar One: a closer look at the proposal’s impact and the questions that remain

October 14, 2020

Philippe Paumier of VECTOR TP, Paris, takes a closer look at the supporting impact analysis of the OECD blueprint on pillar one and considers the future of the proposal . . .

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

G20

OECD Secretary-General reports on status tax policy initiatives to G20 finance ministers: OECD→

October 12, 2020

Digital Economy

OECD should reconsider formulary methods as pillar one and two do not benefit small and poor countries and are too complex, civil society group says: The BEPS Monitoring Group→

October 12, 2020

Europe

The economics of leasing and the arm’s length standard

Dr. Harold McClure, an New York City economist, presents a model of what would compensate arm’s length lease payments and applies this model to ship leasing . . .

Denmark

Denmark tax tribunal considers sufficiency of transfer pricing documentation

Susi Baerentzen, Ph.D., Copenhagen, discusses a decision of the Danish National Tax Tribunal, published on September 24 which assesses the Danish tax administration’s discretionary transfer pricing assessment power. . . .

Americas

US corrects final tax regs on income subject to a high rate of foreign tax: Department of Treasury / Federal Register→

Americas

US IRS issues final BEAT regulations: Department of Treasury→

Americas

Peru postpones some country-by-country report submissions

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses September 28 Peru guidance which alters the procedure for the submission of country-by-country reports on multinational group entities . . .

Americas

Cayman Islands Premier welcomes island’s removal from EU tax blacklist: Ministry of Financial Services, Cayman Islands →

Digital Economy

Spain’s upper house passes financial transactions tax, digital services; both taxes to go into effect in January: Cristina Enache / Tax Foundation→

Americas

Barbados appalled at EU’s “unjust” and “disproportionate” decision to list the Island as a non-cooperative jurisdiction for tax purposes, Prime Minister says: NationNews→

Americas

US IRS issues final regs on withholding and information reporting for dispositions of partnership interests engaged in US trades or businesses: US Treasury→

Denmark

Draft Danish bill would tighten transfer pricing rules

Susi Baerentzen, Ph.D., Copenhagen, discusses proposed changes to Denmark’s transfer pricing law, released for public consultation on October 4 . . .

Asia-Pacific

The EU’s latest list of non-cooperative tax jurisdictions

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses October 6 revisions to the EU Commission’s list of non-cooperative jurisdictions in taxation . . .

Belgium

The new Belgian government’s agreement: a symphony with tax notes

Geoffroy Galéa, Of Counsel and Head of the Tax Practice at Fieldfisher, Brussels, discusses a policy paper, agreed to September 30 by Belgium’s new government, the so-called “Vivaldi coalition,” which includes the coalition’s position on international tax matters . . .

OECD to provide update of global tax negotiation on Monday