Latest

Oliver Treidler and Tom-Eric Kunz, of TP&C GmbH, Berlin, discuss a proposed law introduced by Germany’s Ministry of Finance on December 10 that would have a substantial impact on day-to-day transfer pricing in Germany . . .

Belgium

Belgium gazettes law clarifying earnings stripping rules: KPMG→

Asia-Pacific

Austrian coalition plan endorses corporate tax rate to drop from 25% to 21%: Reuters→

Asia-Pacific

Taiwan changes monetary thresholds for country-by-country reporting: Deloitte→

Europe

Germany’s new R&D tax incentive enters into effect: Karen Hensley-Chelstowska / Duff & Phelps→

Asia-Pacific

Malaysia announces measures to prevent double taxation from digital services tax: Chester Tay / The Edge Markets→

Americas

US IRS updates guidance on obtaining private tax rulings

The US IRS on January 2 issued revenue rulings . . .

Europe

Isle of Man updates guidance on tax residence

The Isle of Man’s Treaty Income Tax Division on January 2 published a practice note addressing . . .

Europe

Ireland updates guidance for obtaining MAP assistance: Irish Tax and Customs→

Americas

Any US trade action over French DST would lead to retaliation and WTO challenge, minister warns: Reuters→

Asia-Pacific

Philippines close to tax treaty with Cambodia, negotiating treaty with Ireland

The Philippines Department of Finance today announced that . . .

Africa

New Cote D’Ivoire law clarifies country-by-country reporting, requires greater tax transparency

Moïse Gnakouri, Ph.D., a researcher at the Catholic University of Louvain, Brussels, discusses a Côte d’Ivoire law published in the official gazette on December 27, 2019, that clarifies country-by-country reporting for multinational groups and that addresses tax evasion . . .

Americas

Google to end use of ‘Double Irish, Dutch sandwich’ tax loophole: Edward Helmore / The Guardian→

January 4, 2020

Americas

Spain poised to enact digital services tax despite US threats of retaliation

January 2, 2020

Alma Delia Virto Aguilar, Ph.D., a visiting researcher at the University of Salamanca, discusses Spain’s plans to enact a digital services tax on the revenue of large multinationals . . .

Asia-Pacific

Hong Kong announces entry into force of Cambodia, Estonia tax treaties

The Hong Kong government on December 27 announced that new tax treaties with Cambodia . . .

Digital Economy

Estonia won’t enact a digital tax, minister says: ERR→

Asia-Pacific

Google settles Australian tax dispute spanning 2008–2018 for AUD 481.5m (USD 336.7): Ben Butler / The Guardian→

Asia-Pacific

Malaysia’s 6% digital services tax to take effect Jan.1: Clarissa Chung / The Star Online→

Europe

2020 Dutch Tax Plan passes: relevance for multinational enterprises

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, provide an update on the Dutch 2020 tax plan which significantly changes the taxation of multinationals . . .

OECD publishes updated country-by-country reporting guidance, notification requirements

The OECD on December 23 released additional interpretative guidance on country-by-country . . .

Asia-Pacific

New Zealand–China tax treaty enters into force

The New Zealand government has announced that the . . .

Asia-Pacific

Japan, Uzbekistan tax treaty signed

Japan’s Ministry of Finance has announced . . .

Asia-Pacific

Hong Kong extends local entity country-by-country filing deadline

Hong Kong’s Inland Revenue Department on December 19 announced . . .

Digital Economy

EU Parliament adopts resolution supporting an EU-wide digital tax should global negotiations fail: European Parliament→

Asia-Pacific

Jordan signs BEPS MLI tax agreement to fight tax avoidance

Jordan on December 19 signed the . . .

Multinational

Professors say that magnitude of BEPS problem is overstated due to incorrect accounting treatment of indirectly owned foreign affiliates: Jennifer Blouin & Leslie A. Robinson / SSRN→

Europe

Multilateral tax treaty to enter into force for Liechtenstein

Liechtenstein on December 19 deposited its instrument of acceptance of . . .

Africa

Shell publishes country-by-country tax report

Oil giant Royal Dutch Shell on December 17 published its country-by-country report data for 2018 on the internet, providing . . .

Asia-Pacific

Turkey enacts 7.5 percent digital service tax

Ramazan Biçer, at partner at Centrum, Istanbul, discusses the details of Turkey’s 7.5 percent digital services tax on the revenue of large multinationals, enacted into law earlier this month and set to go into effect April 1, 2020 . . .

Americas

Officials discuss aligning Brazil’s transfer pricing laws with OECD standards

December 20, 2019

Francisco Lisboa Moreira, a tax partner, Bocater Advogados, São Paulo, discusses Wednesday’s public joint-meeting between OECD and Brazil’s tax authority which again addressed aligning Brazil’s transfer pricing regime of Brazil with OECD standards . . .

Africa

US Treasury official defends “pillar one” safe harbor proposal for new global tax rules

December 20, 2019

A senior US Treasury official on December 19 said that the US is recommending that the OECD’s proposal for a “unified approach to pillar one” be rewritten as an optional safe harbor rule because even a watered-down version . . .

Africa

Singapore, Tunisia tax treaty enters into force

The government of Singapore has announced that . . .

Americas

US IRS publishes proposed tax regs on allocation and apportionment of deductions and foreign taxes, financial services income, other topics

The US today published proposed tax regulations related to . . .

Americas

Japan, Jamaica sign first tax treaty

Japan’s Ministry of Finance on December 17 announced . . .

Americas

US IRS publishes final tax regulations on dividend equivalents

The US today published final tax regulations on dividend equivalents . . .

Asia-Pacific

Israeli court sides with Broadcom, concludes that business restructuring does not trigger tax