Latest

Denmark

Denmark eyes taxing banks, the wealthy to fund early retirement plan: The Hill→

Americas

US IRS now accepting applicants for 2021 Compliance Assurance Process program, allowing large publicly traded corps real-time tax issue resolution: Internal Revenue Service→

Africa

Ukraine, Kenya agree to negotiate tax treaty: Ukrinform→

Europe

UK publishes 2019 report on likely profile of intermediaries affected by DAC6 disclosure, impact on cross-border arrangements: HM Revenue and Customs→

Americas

New Brazil digital services tax law under discussion

August 26, 2020

Francisco Lisboa Moreira, a Tax Partner at Bocater Advogados, São Paulo, Brazil, and Doris Canen, an International Tax LLM at Kings College/UK, São Paulo, Brazil, write about a Brazil bill, submitted August 18, which proposes to tax large tech companies on gross income derived from digital services provided to Brazilian customers . . .

Europe

EU states’ compliance with tax avoidance directives assessed in Commission report

August 26, 2020

Davide Anghileri of the University of Lausanne, Switzerland, discusses an August 19 EU Commission report discussing the extent to which EU states have implemented the anti-tax avoidance directives commonly referred to as the “ATAD” . . .

Multinational

Profs suggest new global rules requiring MNEs to pay more tax in their home country to make up for low effective tax rates paid in other countries: Kimberly A. Clausing, Emmanuel Saez, Gabriel Zucman / SSRN→

August 26, 2020

Digital Economy

UK denies report it’ll end digital tax to get a trade deal with the US: Silvia Amaro / CNBC→

Americas

Covid-19 has accelerated foreign governments’ need to collect tax revenue from digital giants and the risk of US-led trade war: Vijay Govindarajan, Anup Srivastava , Hussein Warsame, & Luminita Enache / Harvard Business Review→

Asia-Pacific

MasterCard’s application before India’s High Court: the equalisation levy dilemma!

Ashish Sodhani, Leader, International Tax, at Nishith Desai Associates, Mumbai, discusses the Delhi High Court’s August 18 ruling on MasterCard’s petition to stay payment of the equalisation levy. . . .

Europe

German finance minister “very confident” pillar one and two blueprints for digital economy will be agreed to in autumn: Reuters→

Americas

India’s Google tax contributes 1% of direct tax in IT hubs of Bengaluru and Hyderabad despite expansion to online e-commerce: Shrimi Choudhary / Business Standard News→

Asia-Pacific

Australian government advises that it will ask large entities to confirm information to be disclosed in legislatively mandated corporate tax transparency report next month: Australian Taxation Office→

Digital Economy

Facebook agrees to pay France USD 118m for 2009–2018 back taxes, advises it began reporting advertising revenue in France from 2019: Mathieu Rosemain / Reuters→

Africa

Facebook to charge Zimbabwe advertisers VAT

Nyasha Nigel Machiri of Baker Tilly Chartered Accountants, Zimbabwe, discusses Facebook’s announcement that they will be charging Zimbabwe advertisers value-added tax on the sale of ads . . .

Africa

The revised operating lease accounting standards: what are the implications for transfer pricing?

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Americas

Colombian tax office launches new platform allowing registration of commodities agreements for transfer pricing purposes

Laura Pinilla, an associate with BaseFirma Colombia, discusses a form released August 3 by the Colombian tax office, which is part of a new platform requiring taxpayers subject to the transfer pricing regime to register agreements related to transactions that involve commodities . . .

Americas

US publishes final regs on dividends received deduction limits, proposes regs on extraordinary distributions and GILTI

The US IRS and Treasury on August 21 published final regulations (T.D. 9909) on limitations . . .

Americas

Colombia publishes guidance on taxation of indirect transfers

Cindy Simbaqueva, a transfer pricing manager at BaseFirma Colombia, Bogotá discusses August 10 guidance issued by the Colombian tax authority related to the taxation of indirect transfers . . .

Asia-Pacific

Australian alert addresses multiple entry consolidated groups that avoid capital gains tax through transfer of assets to an eligible tier-1 company prior to divestment: Australian Taxation Office→

Americas

US notifies Hong Kong of intent to terminate agreement allowing international shippers to avoid double tax: US Department of State→

Europe

Italy enacts DAC6 directive into law effective August 26: Giorgio Vaselli / Withersworldwide→

Africa

Egypt parliament approves MLI: Egypt Today→

Asia-Pacific

Malaysia updates tax guide for foreign digital services providers: Royal Malaysian Customs Department→

Asia-Pacific

Oman State Council proposes draft income tax amendments allowing for exchange of tax information with other countries consistent with international agreements: Times Of Oman→

Asia-Pacific

Hong Kong-Macao tax arrangement enters into force

Hong Kong’s Inland Revenue Department on August 21 announced that an arrangement with Macao for the avoidance of double taxation entered into . . .

Americas

US IRS makes correcting amendments to final regs on outbound property transfers and stock distributions by domestic corporations: Federal Register→

Europe

UK HMRC updates Corporate Finance Manual to address impact of interest restriction on group or consortium loss relief: GOV.UK→

August 20, 2020

Americas

California holds hearing on bill requiring large corporations to publically disclose tax liability, tax credits claimed: Eversheds Sutherland SALT Shaker→

Europe

Russia, Malta agree to amend treaty to raise withholding tax rate for interest, dividend payments to 15 percent: Reuters→

Americas

Brazil lower house speaker Rodrigo Maia will oppose financial transactions tax, digital tax: Reuters→

Asia-Pacific

Draft Australian transfer pricing guidance addresses interest-free loans, debt vs. equity conundrum

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP, discuss August 12 draft transfer pricing guidance issued by the Australian Taxation Office outlining its proposed risk assessment of outbound interest-free loans made to related parties . . .

Asia-Pacific

India publishes synthesized text of tax treaty with Ukraine adding MLI changes: Government of India Income Tax Department→

Asia-Pacific

Singapore proposes to strengthen GAAR, introduce tax avoidance surcharge