Latest

Europe

EU Commission will announce whether it will appeal Apple/Ireland tax ruling closer to September 25 deadline for filing an appeal, Vestger says: Naomi O’Leary, Joe Brennan / Irish Times→

Digital Economy

UK regulations on overdue or overpaid digital services taxes published: Legislation.gov.uk→

Americas

US professors advocate increasing corporate tax rates to tax “economic rents”, the supersized returns that accrue to capital owners when companies enjoy market power or other non-reproducible advantages: Edward G. Fox & Zachary D. Liscow / SSRN→

Asia-Pacific

Tax Inspectors Without Borders, a joint OECD/UNDP initiative, has launched its first program in Kazakhstan: TIWB / Twitter→

Asia-Pacific

Asian Development Bank to launch hub to promote knowledge sharing and strengthen cooperation on tax policy and administration in Asia and Pacific regions: Asian Development Bank→

Multinational

Dutch multinational Philips to publish its country-by-country reporting data, Oxfam tax policy expert notes: Johan Bernardo Langerock / Twitter→

Europe

Guernsey updates economic substance regs relating to self-managed CIVs effective October 1: Government of Guernsey→

Asia-Pacific

Australia notes noncompliance with international dealings schedule disclosures regarding hybrid mismatches (question 49): Australian Taxation Office→

Americas

The transfer pricing implications of Armani’s US advertising payments

New York City economist Dr. Harold McClure discusses a difficult transfer pricing issue often faced by multinational apparel and shoe manufacturers, namely, how to treat locally incurred advertising expenses where the foreign parent formally owns the trademarks . . .

Americas

US IRS again defers start date of foreign currency tax regulations

The US IRS has again deferred the applicability date of foreign currency . . .

Digital Economy

EU will propose its own digital tax plan if global agreements “fall short of a fair tax system that provides long-term sustainable revenues,” President von der Leyen says: European Commission→

Europe

Russia considers RUB 90 billion (USD 1.2 billion) in tax increases, hitting tobacco and tripling the mineral extraction tax except on gold, diamonds, and coal extraction but adding oil extraction: Reuters→

Asia-Pacific

New Zealand provides Covid-19 transfer pricing guidance

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP, New Zealand, discuss recently released New Zealand Inland Revenue transfer pricing guidance for businesses affected by Covid-19 . . .

Europe

Poland proposal would require large companies to make their tax policies public

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses corporate taxation legislative changes proposed by Poland’s Minister of Finance on September 4 applicable to large corporations . . .

Americas

The protectionism of Biden’s cross-border tax plan

Daniel Bunn, Vice President of Global Projects at the Tax Foundation in Washington, analyzes US presidential candidate Joe Biden’s cross-border taxation proposals, made public last week, which aim to support his “Made in America” agenda . . .

Europe

First Look: Dutch Tax Plan 2021 released

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, note today’s release of Dutch Tax Plan 2021 and highlight some of the most important provisions for multinationals . . .

Europe

Sweden proposes to deny tax deductions for interest payments to companies located in EU blacklist countries

Madeleine Thörning, a transfer pricing specialist at Thorning Koponen Consulting in Stockholm, discusses the Swedish government’s September 3 proposal to deny tax deductions for interest payments made to companies located in countries listed on the European Union’s list of non-cooperative jurisdictions . . .

Digital Economy

Spain aims to tax revenue of companies that provide communications services such as instant messaging and calls: Reuters→

Asia-Pacific

Indonesia, Australia agree to automatic exchange of tax information: Vietnam+→

Americas

US publishes official version of interest expense deduction regs, changing them slightly from advance copy

The US IRS today published in the Federal Register final regulations that provide guidance on the business interest expense deduction limitation . . .

Bulgaria

Bulgaria, Netherlands sign new tax treaty: The Sofia Globe→

Europe

EU countries lost about €140 billion VAT revenues in 2018, a marginal improvement over prior years, report concludes: European Commission→

Digital Economy

Not all forms of legal tax planning are socially legitimate; corporations should pay their fair share, develop tax codes of conduct, provide tax transparency, researcher argues: Ave-Geidi Jallai / SSRN→

Asia-Pacific

Indonesia, Australia sign agreement to exchange tax information: The Jakarta Post→

Americas

Biden pledges to immediately reverse corporate tax cuts, raising rates to 28% from 21%: Joseph Zeballos-Roig / Business Insider→

Americas

Deriving receipts from New Jersey sources does not give foreign corporate limited partner nexus for corporate business tax purposes, court says: Eversheds Sutherland→

G20

G20 should encourage better design of tax expenditures that have implications for international trade, authors say: Agustín Redonda, Facundo Calvo, Gilles Carbonnier, Irma Mosquera Valderrama, Rahul Mehrotra, Robert Koopman / Think20→

Europe

Poland to offer additional tax breaks for investments in automation or training employees to operate robots: The First News→

Europe

EU Commission will assess EU General Court’s Apple ruling, including burden of proof issue, before deciding next steps for other State aid tax challenges: Margrethe Vestager for European Commission / European Parliament→

International Monetary Fund

MNE tax system is failing because it is incompatible with increasing global business integration, digitalization, services and intangibles trade, IMF author says: Shafik Hebous / International Monetary Fund→