Latest – Page 5 of 157

Americas

Mexico’s 2022 income tax law takes effect, incorporates notable transfer pricing changes

February 14, 2022

Francisco Arballo, Grupo Consultor EFE, discusses Mexico’s 2022 income tax law, which went into effect in January, incorporating several amendments the Mexican legislature proposed in September 2021, including various changes in transfer pricing.

Denmark

Danish Tax Agency issues clarification on master file filing requirements

February 14, 2022

Joel André Malan, Danish Tax Agency, discusses new Danish guidance, published on January 31, stating that a taxpayer unable to provide a master file for a given year can be granted a temporary reprieve, providing that three conditions are met.

Asia-Pacific

Iran, Finland sign tax treaty: Tasnim News Agency→

February 14, 2022

Europe

EU Commission’s EU Chips Act offers €11 billion R&D partnership to boost R&D, manufacturing of semiconductors: Hogan Lovells / JD Supra→

February 11, 2022

Americas

IRS answers research credit claims (section 41) on amended returns: Internal Revenue Service→

February 11, 2022

OECD launches public consultation on Pillar One draft model rules on revenue sourcing and nexus

February 10, 2022

Nyasha Nigel Machiri, HLB Zambia, discusses the OECD announcement that it is seeking public comment by February 18 on recently released draft model rules with respect to nexus and revenue sourcing under Amount A of Pillar One as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the two-pillar solution.

Americas

Trinidad and Tobago: Court of Appeal quashes treaty shopping scheme

February 9, 2022

Allan Lanthier, a former advisor to the Canadian government, analyzes the recent treaty shopping decision of Trinidad and Tobago’s Court of Appeal – a decision that stands in stark contrast to the recent treaty shopping decision of the Supreme Court of Canada in the Alta Energy case.

Africa

Lesotho, Thailand, and Vietnam sign multilateral convention to implement tax treaty-related measures to prevent BEPS: OECD→

February 9, 2022

Accounting

Bridging the gap between tax and accounting rules: Cavanaugh / CrossBorder Solutions→

February 9, 2022

Europe

Year-end transfer pricing adjustments and DAC6 obligations in Italy: an additional administrative burden for MNEs?

February 8, 2022

Luca Tortorella, Gatti Pavesi Bianchi Ludovici, discusses the Italian Revenue Agency’s December 31 resolution clarifying that year-end transfer pricing adjustments may be communicated for DAC6 purposes; DAC6 introduces complicated features and adds further reportable obligations.

Asia-Pacific

China uses big data to crack down on multinational companies involved in tax evasion

February 8, 2022

Hengka (Henry) Ji and Zihan Zhang, Zhong Lun Law Firm, discuss China’s January 26 announcement that tax authorities across the country will begin to rely more on big-data analytic resources to detect tax evasion by big businesses and individuals.

Europe

The EU means business when it comes to shell companies: Crossborder Solutions→

February 7, 2022

Asia-Pacific

India’s budget looks to tax cryptocurrencies, extending India’s tax base

February 7, 2022

Mukesh Butani and Seema Kejriwal, BMR Legal Advocates, discuss India’s budget announced on February 1, which carries key tax amendments affecting multinationals doing business in India.

Americas

Mexico says adios to advanced pricing agreements for maquiladoras: CrossBorder Solutions→

February 7, 2022

Americas

US House passes chips funding bill, could provide US $52 billion in R&D, production funding for semiconductor companies in US: Secard / Industry Week→

February 7, 2022

Americas

Build Back Never?

February 3, 2022

It was an end-of 2021 cliffhanger: Throughout the fall, Build Back Better was gaining momentum, making headlines, and finally, in November, passing through the House in a 220-213 vote. It had just one more hurdle: to pass through the Senate. Now that is looking increasingly unlikely.

Africa

Niger finance bill amends article on taxation of income from transferable securities

February 3, 2022

Moïse Gnakouri, Catholic University of Louvain, discusses the Niger parliament’s December 20, 2021 adoption of the 2022 finance bill, which makes many tax changes, including an amendment of the article concerning the taxation of income from transferable securities.

Europe

Montenegro introduces new landmark transfer pricing rules, corporate tax changes

February 1, 2022

Slobodanka Kolundžija, freelance tax advisor, discusses the Montenegrin parliament’s December 31 introduction of a new landmark set of transfer pricing rules, requiring companies to prepare and file transfer pricing documentation from . . .

Czech Republic

Italy’s new clarifications concerning VAT treatment of transfer pricing adjustments

February 1, 2022

Diletta Fuxa, Studio Associato Servizi Professionali Integrati, discusses the Italian tax authority’s December 30 release regarding the VAT treatment of transfer pricing year-end adjustments in its response to . . .

Africa

UAE announces 9% corporate income tax rate, sets tone on regional corporate tax competition

January 31, 2022

Mourad Chatar and Sarah Bahous, Value Square, discuss the United Arab Emirates’ January 31 announcement that it will implement a federal corporate tax regime at a standard nine percent rate, which will apply to relevant businesses from . . .

Americas

Paraguay requires new transfer pricing section on income tax return

January 31, 2022

Francisco Arballo, Grupo Consultor EFE, discusses Paraguay’s December 30, 2021 publication of a new income tax return format, including a new section differentiating the transfer pricing adjustments made to intercompany transactions based on the sixth method, which is . . .

Europe

French 2022 finance law includes tax measures affecting MNEs

January 28, 2022

Patrick Donsimoni, La Boetie, discusses tax measures in the 2022 French finance law, published in the French Official Gazette on December 31, 2021, affecting multinational groups that have . . .

Belgium

EU draft directive to tackle “shell entities”: ATAD III or the European Magnificent Seven-step approach

January 28, 2022

Geoffroy Galéa, Alain Thilmany, and Cassandre Guéry, Fieldfisher, discuss the European Commission’s 22 December 2021 publication of the ATAD III directive, which will increase the tax authorities’ attention to the international concept of substance; more than ever, it is crucial for multinational groups to . . .

Accounting

What do you need to know about the valuation allowance? Telson / CrossBorder Solutions→

January 28, 2022

More News

The IRS’s new R&D documentation demands: CrossBorder Solutions→

January 26, 2022

Asia-Pacific

Sri Lanka to sign new tax treaties with India, Czech Republic, Turkey: Daily Mirror Online→

January 26, 2022

Europe

Swedish Administrative Court of Appeal did not consider multiple-year data, adjusted the taxable result

January 26, 2022

Emiliha Ferrão, Censio Tax, discusses Sweden’s Administrative Court of Appeal’s November 2021 ruling in favor of the Swedish Tax Authority in a case involving a change of transfer pricing methodology and a restrictive use of multiple-year results to support . . .

Digital Economy

EU consults on adapting VAT rules to digital age

January 21, 2022

The European Commission on January 21 announced the launch of a consultation on how the value-added tax (VAT) system can be updated to adapt to the digital economy and new business models while also reducing burdens and costs for businesses; the consultation is being held in advance of . . .

Multinational

Global minimum tax safe harbor with simplified effective tax rate calculation for low-risk countries could ‘tremendously reduce reporting obligations and compliance costs for MNEs’: Döllefeld, Englisch, Harst, Schanz & Siegel / SSRN→

January 21, 2022

OECD transfer pricing guidelines get first update in five years

January 20, 2022

In the new 2022 edition of the OECD’s transfer pricing guidelines released on January 20, the OECD has made three significant additions and revisions to the guidelines for multinational enterprises and tax administrations, reflecting several enhancements developed over . . .

Europe

UK seeks feedback on revised uncertain tax treatment guidance

January 19, 2022

The UK government on January 18 launched a consultation on revised draft guidance on the upcoming uncertain tax treatment notification requirement for large businesses, reflecting amendments received in response to . . .

Americas

US Senate Finance Chair looking into pharma international tax abuse

January 19, 2022

Pharmaceutical industry tax practices involving the use of offshore subsidiaries to avoid paying US taxes are the target of an investigation by US Senate Finance Committee Chair Ron Wyden (D-Ore.), who requested information from Bristol Myers Squibb on January 18; this latest information request follows a similar letter sent to . . .

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Asia-Pacific

Taiwan highlights changes in new tax treaty protocol with UK

January 18, 2022

Taiwan’s Ministry of Finance on January 18 explained the changes in the new amending protocol to the UK-Taiwan tax treaty, which took effect on January 1 after entering into force on . . .

Americas

Colombian regulation addresses ultimate beneficial owner report for tax purposes

January 18, 2022

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian tax administration’s implementation of a regulation on the registration of the ultimate beneficial owner-report for tax purposes, which entered into force on January 15, and establishes . . .

Belgium

Belgian court rules on application of tax general anti-abuse provision

January 18, 2022

Moïse Gnakouri, Catholic University of Louvain, discusses the Belgian High Court’s two November 25 decisions in tax matters concerning the general anti-abuse provision contained in article 344 of the Belgian Income Tax Code, as applied to . . .

Europe

Finnish R&D study supports use of tax incentives to spur growth

January 14, 2022

Finland’s Ministry of Finance on January 13 announced the results from a research report reviewing the effectiveness of subsidies for research and development (R&D) activity, stating that the results support the use of R&D tax incentives as “proper policy” in Finland; however, while the report found that open-use R&D subsidies like tax incentives are . . .

Asia-Pacific

Malaysia clarifies rules on tax treatment of R&D expenditures

January 14, 2022

The Inland Revenue Board of Malaysia on December 29 published an updated public ruling explaining the rules relating to qualifying research and development (R&D) expenditures for tax incentive deductions; businesses resident in Malaysia that undertake R&D activity may be able to . . .

Americas

Poland transfer pricing laws under review to strengthen system against tax evasive behavior

January 14, 2022

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s participation since November in a project coordinated by the European Commission to reform Polish transfer pricing regulations; the project is planned to . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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