Latest

Americas

Canada addresses COVID-19 travel restrictions’ effect on tax residency, PEs: KPMG→

Americas

US IRS relaxes rules on dual consolidated loss, Form 8858 filing in response to COVID-19 travel disruption

The US IRS this week announced that in some cases where individuals temporarily conduct . . .

Europe

Following similar decisions by other EU states, Scotland bans COVID-19 support to firms based in tax havens: Severin Carrell / The Guardian→

Europe

EU Advocate General addresses UK’s VAT exemption for cost-sharing groups

Francesca Amaddea, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the conclusions of Advocate General Juliane Kokott issued April 23 concerning a case before the European Court of Justice on the operation of the VAT exemption for cost sharing groups when a third country is involved . . .

Africa

Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches

May 26, 2020

Hugo Chary and Thibaut Roques of TP qube, Paris / Bordeaux, France, discuss how to adjust comparable company searches to reflect the new market conditions that have arisen from the COVID-19 crisis . . .

Americas

IRS corrects foreign tax credit regs: Internal Revenue Service→

Featured News

Netherlands Supreme Court addresses taxation of perpetual securities under debt/equity rules

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss an important Netherlands Supreme Court decision published May 15 which considered whether perpetual loans should be viewed as debt or equity for tax purposes . . .

Asia-Pacific

Philippine senator proposes tax on digital content, advertising, online marketplaces: The Star→

Africa

Countries still can’t agree on update to multinational group taxation rules, OECD official says

The 137 countries that make up the “Inclusive Framework on BEPS” are having a difficult time reaching agreement on an update to the global rules for allocating multinational group profits among nations, according to Pascal Saint-Amans, OECD Center for Tax Policy and Administration. Saint-Amans warned. . .

Featured News

Italy’s Supreme Court rules on VAT treatment of intercompany management fees

Gian Luca Nieddu, Partner, Transfer Pricing & Tax Value Chain, Hager & Partners, Milan area, discusses a recent decision, of Italy’s Supreme Court which addressed the VAT deductibility of intercompany charges accomplished by the reverse charge mechanism . . .

Africa

Kenya’s Finance Bill 2020 proposes new digital services tax, amnesty, other measures

George Maina, a tax partner at Rodl & Partner, Kenya, discusses May 5 Kenya government tax proposals in Finance Bill 2020, which include a digital services tax and minimum tax . . . .

Asia-Pacific

Hong Kong government advances Hong Kong-Macao tax treaty: Inland Revenue Department→

Asia-Pacific

Australia updates GAAR guidance: Australian Taxation Office→

Costa Rica

OECD invites Costa Rica to join as 38th member: OECD→

Americas

US and lawmakers and officials to propose tax breaks to encourage companies to move operations out of China: Reuters→

Europe

EU court rules on legality Italy-Portugal tax treaty’s pension taxation scheme

May 18, 2020

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the European Court of Justice’s April 30 decision addressing a challenge to the legality of the pension scheme under the double taxation convention between Italy and Portugal . . .

Asia-Pacific

Saudi Arabia to triple VAT rate to 15 percent, suspend cost of living allowance: BBC News→

May 15, 2020

Asia-Pacific

India amends rules for resolution of tax disputes under MAP

May 15, 2020

Ritu Shaktawat, a partner at Khaitan & Co., Mumbai, discusses May 6 India government amendments to the rules for accessing the mutual agreement procedure (MAP) in tax treaties . . .

Americas

US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure

Elisa Kaminsky, Transfer Pricing Manager, at BaseFirma, Miami, discusses a US Tax Court decision issued on May 5 which resolved a tax dispute between Whirlpool and the IRS concerning a maquiladora structure . . .

Polish government issues Q&A on APA procedure: Krajowa Administracja→

Europe

Italy’s financial transaction tax complies with EU law, court rules

Francesca Amaddeo a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, analyzes a long-awaited decision of the European Court of Justice, released on April 30, that concludes Italy’s financial transaction tax on derivatives of equity transactions is compatible with EU law . . .

Asia-Pacific

BEPS MLI to enter to force for Czech Republic, Korea

The OECD today announced that the Czech Republic and Korea have deposited their . . .

Featured News

US IRS finalizes section 385 debt/equity “distribution regulations,” promises further study

The US IRS today issued final regulations under section 385 on the treatment of certain interests in corporations as stock . . .

Featured News

First Look: OECD consults on review of country-by-country reporting scheme for multinationals

The OECD today wrapped up a two-day public consultation reviewing the country-by-country reporting scheme for multinational groups. The meeting, held remotely via . . .

Americas

US IRS assisting taxpayers with APAs during downturn, relaxes APA and MAP filing requirements

The US IRS has advised that it is willing to assist taxpayers that have executed an advance . . .

Asia-Pacific

Synthesized text of Australia-Norway tax treaty as modified by BEPS MLI published: Australian Taxation Office→

Europe

EU Commission extends deadlines for VAT e-commerce rules, DAC reporting