Latest

Asia-Pacific

Australian patent box R&D tax rules bill introduced in parliament

Sam Lo Ricco, Nuwaru, discusses the long-awaited patent box rules bill introduced in Australia’s parliament on February 10, covering medical or biotechnology patents that could allow taxpayers to benefit from a concessional tax rate of 17%.

Asia-Pacific

Bahrain, Romania deposit instruments of ratification for BEPS MLI with the OECD, joining 70 other countries; entry into force is June 1, for both countries: OECD→

Americas

Sec. 41 research credit, how statistical sampling can help satisfy four-part test governing whether research activities qualify for the credit: Song, Ashtiani, Seo, Martin, Benton, Dallas & Rotz / The Tax Adviser→

Americas

A regulatory tax hike on US multinationals

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Europe

International taxation: two-pillar plan and the OECD mainstream

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the February 21 virtual “OECD Tax Talks” webinar to assess the world’s progress in implementing the historic OECD/G20 two-pillar international tax package.

Europe

Spain’s annual guidelines on tax and customs controls focus on transfer pricing issues

Abigail Blanco Vázquez and Mario Ortega, J&A Garrigues, S.L.P., discuss the Spanish tax agency’s January 31 publication of the general guidelines of the 2022 Annual Tax and Customs Control Plan, containing transfer pricing changes, including a new automated transfer pricing risk analysis system.

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

American Samoa

EU Council keeps 9 jurisdictions on `harmful’ tax practices blacklist: American Samoa, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands and Vanuatu: Council of the European Union→

February 25, 2022

Asia-Pacific

Greece, Australia start tax treaty negotiations: Papadopoulos / Greek City Times→

February 25, 2022

Asia-Pacific

India refunds US $1.1 billion to UK-based Capricorn Energy (formerly Cairn) to settle tax dispute: BusinessLine→

February 25, 2022

More News

‘OECD Tax Talks’ presentation slides: OECD→

Americas

The road to audit-proof transfer pricing documentation: Song / CrossBorder Solutions→

Americas

Apple v. European Commission: Outcome could strengthen or weaken Commission’s success in challenging lack of arm’s length principles in TP methods through state aid concerns: Cantley and Dietrich / SSRN→

Europe

Romania approves changes to advance tax ruling program

Adrian ȚAGA, Romania’s National Tax Agency, discusses the Romanian government’s February 16 approval of changes to the organizational structure of both the Ministry of Finance and the National Tax Agency, allowing the transfer of the advance tax rulings (ATR) unit to the Ministry of Finance.

OECD launches public consultation on Pillar One draft model rules for tax base determination

Nyasha Nigel Machiri, HLB Zambia, discusses the OECD’s February 18 announcement that it is seeking public comment by March 4 on its draft model rules for tax base determinations under Amount A of Pillar One.

Americas

The applicability of the Spanish GAAR to conduit structures after the CJEU Danish cases

Aitor Navarro, Carlos III University, discusses the Spanish tax authorities’ December 16, 2021 publication of a panel report on the applicability of the domestic GAAR to a conduit arrangement aimed at benefiting from an exemption at source on the payment of interest income to EU residents.

Africa

Kenya: embracing the two-pillar approach

Samuel Okumu, Rödl & Partner Limited, discusses the OECD-Kenya Revenue Authority’s three-day workshop in Naivasha, Kenya in late January to assess Kenya’s efforts in enacting the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS).

Asia-Pacific

R&D in New Zealand: fresh thinking for an innovation culture: Clowney / CrossBorder Solutions→

Accounting

Income tax provision: what’s the rush about?: Cavanaugh / CrossBorder Solutions→

More News

Public comments released on OECD draft rules for nexus, revenue sourcing under Pillar One Amount A (63 entries): Dropbox.com→

Americas

USTR prods Canada to scrap digital services tax: Office of the US Trade Representative→

Asia-Pacific

Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25: Yuen / Marketing-Interactive.com→

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

Asia-Pacific

Singapore considers `top-up’ tax to raise MNE group tax rate to 15%: Kit / Channel News Asia→

More News

OECD seeks public comments by Mar. 4 on draft rules for tax base determinations under Amount A of Pillar One→

Europe

Spanish National Court challenges the application of an internal CUP in favor of the TNMM