Latest

Indonesia on April 28 deposited its instrument of ratification for . . .

Americas

Colombia officially joins OECD as 37th member: Modern Diplomacy→

Digital Economy

OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance

The 130+ countries that make up the “Inclusive Framework on BEPS” still aim to reach consensus by the end of 2020 on updated rules for taxing multinational groups; however, disagreement has emerged regarding whether. . .

Europe

Ireland transfer guidance addresses claims for unilateral tax relief

Warren Novis, Head of Transfer Pricing, BDO Ireland, discusses Irish transfer pricing guidance released April 24 on correlative adjustments . . .

EU Commission to investigate whether Netherlands granted IKEA subsidiary State aid by approving tax deductions

May 1, 2020

The European Commission announced April 30 that it has widened the scope of its in-depth investigation into the Netherlands’ tax treatment of an IKEA subsidiary . . .

Europe

New Poland transfer pricing risk assessment tool released in interactive format

Dr. Monika Laskowska of the Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish government’s newly launched an interactive version of its transfer pricing risk assessment tool which requires taxpayers to disclose to tax authorities much more information than required in the past . . .

Europe

Finland transfer pricing rules analyzed in landmark court rulings

Visa Randell, LL.M., M.Sc. (Econ.), Helsinki, discusses two important transfer pricing decisions of Finlands’ Supreme Administrative Court, released April 2; one concerns a sales company that incurred losses over multiple years and the other involves the tax authority’s attempt to restructure a transaction for transfer pricing purposes . . .

Europe

Taxation of cross-border workers in southern Switzerland uncertain during COVID-19 pandemic

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland writes that the taxation of many of the almost 70,000 Italians that formerly crossed the border to work in Switzerland is now uncertain given changes made in response to COVID-19 . . . .

Africa

Kenya passes corporate tax rate cut, modifies turnover tax and withholding tax

George Maina, a Tax Partner at Rodl & Partner, Kenya – East Africa, discusses new Kenya tax law amendments, signed into law April 25, designed to be permanent changes to the tax code and to also immediately protect individuals and businesses from the adverse impact of COVID-19 . . .

Asia-Pacific

Hong Kong revises guidance on advance tax rulings

Agnes Lo of Lingnan University and Raymond Wong, City University of Hong Kong discuss Hong Kong Inland Revenue Department guidance issued April 16 on advance tax rulings . . .

Asia-Pacific

US trade report says India’s equalisation levy impedes trade, risks retaliation: Kirtika Suneja / The Economic Times→

Inclusive Framework on BEPS

Professor argues that BEPS project altered international tax decisionmakers, agenda, norms, legal forms allowing current action on allocation issues: Ruth Mason / SSRN→

Europe

Synthesized text Ireland-Lithuania tax treaty as amended by MLI released: Irish Revenue→

Asia-Pacific

Synthesized text of Ireland-Singapore tax treaty as amended by MLI released: Irish Revenue→

Americas

Former IRS APMA Director Dick McAlonan Joins Alvarez & Marsal Taxand’s Washington DC office: Alvarez & Marsal Taxand→

Poland planning 1.5 percent surcharge on video-on- demand revenue, minister says: Reuters→

Asia-Pacific

Pakistan income tax collection from services falls 20 percent in March: Shahnawaz Akhter / The News→

April 28, 2020

Digital Economy

Germany will use EU presidency to promote financial transactions tax, minimum tax, Merkel says: Reuters→

April 26, 2020

Denmark

France joins Denmark and Poland in barring firms headquartered in tax havens from coronavirus support measures: Bill Bostock / Business Insider→

April 26, 2020

Africa

COVID-19 and the future of Pillar one

Oliver Treidler, CEO, TP&C GmbH, Berlin, considers how the COVID-19 crisis will likely affect global negotiations to reform the taxation of multinational groups, noting that a delay could give transfer pricing practitioners time to formulate an alternative, updated, concept of value creation to replace Pillar one’s formulaic elements . . .

Digital Economy

Poland minister says EU should consider digital tax, financial transactions tax, carbon border tax, and tax haven clampdown to pay for coronavirus costs: James Shotter / Financial Times→

Europe

15 professors advocate shifting power to tax to the EU level in response to coronavirus crisis: EU Law Live→

CIAT

Updated summaries (April 21) of tax administration responses to COVID-19 published: CIAT, IOTA & OECD→

Americas

US IRS issues guidance on COVID-19 travel disruptions’ effect on tax residency, treaty benefits, foreign earned income exclusion

The US IRS on April 21 issued tax guidance explaining how the IRS will view an individual’s unexpected travel disruptions due to the COVID-19 emergency for purposes . . .

Europe

EU publishes notice to stakeholders outlining how UK’s EU withdrawal affects VAT for goods after December 31: European Commission→

Asia-Pacific

China temporarily halts interest on late import tax payments for foreign firms operating in special economic zones: Bloomberg Tax→

Asia-Pacific

India’s new 2 percent equalisation levy on the digital economy enters into force

Vinita Krishnan and Jugal Mundra, Khaitan & Co, Mumbai, discuss in detail India’s new 2 percent equalisation levy, which became effective on April 1 and applies to a broad range of nonresident e-commerce sales and services to Indian customers . . .

Africa

Denmark denies coronavirus aid to companies registered in countries on EU list of noncooperative tax jurisdictions: Nikolaj Skydsgaard / Reuters→

April 21, 2020

Europe

Netherlands and Germany agree on cross-border worker taxation in light of COVID-19

April 20, 2020

Jian Cheng Ku, Rhys Bane, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam, analyze a competent authority agreement executed by the Netherlands and German governments addressing the application and interpretation of Article 14 (income from employment) of the Netherlands-Germany tax treaty in light of recent measures to curb COVID-19 . . .

Africa

US tax policy nonprofit tracks worldwide COVID-19 tax relief: Tax Foundation→

Americas

US IRS reconsidering ruling limiting foreign tax credit carryback

The US IRS today announced that it has suspended Rev. Rul. 71-533, 1971-2 C.B. 413 which concerns. . .

US IRS issues frequently asked questions on transfer pricing documentation, best practices

Elisa Kaminsky of BaseFirma, Miami, discusses IRS frequently asked questions, issued April 15, that aim to provide practitioners with best practices regarding transfer pricing documentation . . .

G20 finance ministers agree to continue work on taxation of digital economy