Latest

Joe Chan, Managing Partner, ATax Advisors Limited and Zaynab Hisaund, Senior Tax Manager, ATax Advisors Limited, discuss Mauritius’ Finance Bill, enacted August 7 . . .

Asia-Pacific

India issues comprehensive guidance on cross-border tax dispute resolution

Ritu Shaktawat, Partner, and Raghav Kumar Bajaj, Principal Associate, at Khaitan & Co, Mumbai, discuss India guidance, released August 7, on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations . . .

Americas

US IRS corrects proposed regs that adjust hybrid deduction accounts to reflect E&P of CFCs included in income by US shareholders: Internal Revenue Service→

Europe

Unilever would not move headquarters from Netherlands if Dutch Green’s proposal for ‘exit tax’ enacted: Reuters→

Europe

Given the outcome in the Apple case, EU should abandon the use of competition policy to fight tax avoidance, move instead toward destination-based income tax: Alan J Auerbach & Michael Devereux→

Multinational

OECD working paper concludes that, rather than being regressive, VAT is roughly proportional or slightly progressive in most of the 27 OECD countries examined: OECD→

Americas

US–Swiss competent authority arrangement implementing tax dispute arbitration published: Internal Revenue Service→

Asia-Pacific

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .

Asia-Pacific

Trump trade adviser Peter Navarro says tax incentives in Ireland, Singapore, Switzerland, India, China that lure pharmaceutical manufacturing away from US are a “significant” problem: Brian O’Donovan / RTÉ→

Cyprus

Russia seeks to update Netherlands, Cyprus, Malta, Luxembourg tax treaty to add 15 percent withholding tax on dividends and interest: Mohammad Ali / UrduPoint→

Asia-Pacific

Israel considers requiring taxpayers to pay disputed tax or transfer pricing assessments pending appeal

Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher of JH Consulting Ltd., Tel Aviv-Yafo, discuss an Israeli proposal to require immediate tax collection if a taxpayer appeals a tax or transfer pricing controversy in district court . . .

Asia-Pacific

Malaysia publishes guide on digital services tax for foreign service providers: Royal Malaysian Customs Department Internal Tax Division→

Asia-Pacific

China adopts integrated circuit, software industry incentives, including income tax exemptions and rate reductions, preferential VAT treatment, import tariff exemptions: China-Briefing→

Americas

Indonesia adds Facebook, TicTok, Amazon, Apple subsidiaries to list of foreign digital companies required to collect 10 percent VAT from customers beginning September: Eisya A. Eloksari / The Jakarta Post→

Americas

Public input sought on Brazil, OECD transfer pricing harmonization

Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

Asia-Pacific

UK guidance updated to state that France, Italy, Malaysia, Turkey taxes are similar to UK’s digital services tax for purposes of cross-border relief: HM Revenue and Customs→

August 5, 2020

Asia-Pacific

Australia updates transfer pricing legislative reference to OECD guidance

August 4, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP discuss July 29 Australian Taxation Office guidance that addresses the application of the OECD transfer pricing guidelines in interpreting Australian law . . .

Cyprus

Russia threatens to withdraw from Russia-Cyprus tax treaty unless Cyprus agrees to 15 percent tax on dividend payments to Cyprus parent corporations: Finanz.dk→

August 4, 2020

Asia-Pacific

India Supreme Court rules Samsung Heavy Industries’ project office is not a permanent establishment under tax treaty

August 3, 2020

Jitendra Jain, Executive Director, Transfer Pricing, PricewaterhouseCoopers Private Limited, discusses the July 22 ruling of the Supreme Court of India in the case of Samsung Heavy Industries Co. Ltd., concerning the preparatory or auxiliary activities exception to permanent establishment . . .

First Look: US IRS issues final and proposed regulations on interest deduction limits

The US IRS on July 28 released final and proposed regulations that implement limits to the tax deduction for interest expense enacted . . .

Europe

UK asks for public feedback on benefits and risks of introducing tax on online sales of products or services: HM Treasury→

Americas

North Carolina announces voluntary transfer pricing resolution initiative: North Carolina Department of Revenue→

Africa

Global Forum publishes toolkit to help countries join global treaty providing for cooperation in tax matters: Global Forum on Transparency and Exchange of Information for Tax Purposes→

Multinational

OECD again updates listing of tax policy measures enacted in response to COVID-19: Twitter / OECDtax→

Americas

Brazil proposal requires foreign digital platforms to collect new consumption tax

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, discusses a bill presented by the Brazilian government to Congress on July 21 that would modify the country’s indirect tax laws and make digital platforms responsible for the tax liabilities of non-resident sellers of physical and digital goods . . .

Asia-Pacific

Philippines President proposes corporate income tax rate cut from 30% to 25%, business tax incentives: Andreo Calonzo / Bloomberg→

International Monetary Fund

PCT webinar addressing new Toolkit on Taxation of Indirect Transfers features presentations by OECD, IMF officials: Platform for Collaboration on Tax→

Africa

OECD reports assess cross-border tax dispute resolution in Andorra, Bahamas, Bermuda, BVI, Cayman Islands, Faroe Islands, Macau, Morocco, Tunisia

The OECD on July 27 published reports approved by a group of 135+ countries known as the “Inclusive Framework on BEPS” that assess . . .

Africa

New IGF, ATAF initiative seeks to improve mining sector taxation: Intergovernmental Forum on Mining, Minerals, and Sustainable Development→