Latest

Honduras has joined the “Inclusive Framework on BEPS” becoming the . . .

Americas

The final and proposed BEAT regulations: what changed, what’s new, and what’s next?

Amanda Varma, a partner with Steptoe & Johnson, Washington, DC, analyzes the final and proposed base erosion anti-abuse tax (BEAT) regulations, issued on December 2 . . .

Africa

New Nigeria circular explains how nonresidents may claim tax treaty benefits: Federal Inland Revenue Service→

Asia-Pacific

UAE finance ministry announces that it has begun to receive CbCR reports: ZAWYA→

Outlook for global consensus on an international tax update appears “bleak,” tax researchers conclude: Rasmus Corlin Christensen & Martin Hearson / Roosevelt Institute→

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

Asia-Pacific

Facebook to collect 6% digital tax in Malaysia beginning January 1: Alexander Wong / SoyaCincau.com→

Americas

France will challenge at WTO any US tariffs imposed in retaliation for DST, Finance Minister says: Geert De Clercq / Reuters→

Europe

Fiat to appeal State aid verdict with EU Court of Justice: Foo Yun Chee & Giulio Piovaccari / The New York Times→

Europe

Why the EU Commission won’t appeal the Starbucks judgment

December 10, 2019

Dimitrios Kyriazis, Head of the Law Faculty at the New College of the Humanities, London, discusses the Commission’s decision to not appeal the Starbucks State and the implications of the Court’s judgment for transfer pricing in Europe . . .

Royalty rates for licensed intangibles and minerals

December 10, 2019

Ednaldo Silva, Founder & Director at RoyaltyStat, discusses the economic concept of royalties . . .

Digital Economy

OECD holds consultation on “pillar two” global tax for multinationals, pledges continued work on “pillar one”

The OECD on December 9 held a public consultation in Paris, providing a forum for stakeholders to express their views on how to best design a “pillar two” global minimum tax on multinational group profit, also known . . .

Americas

US publishes US-France joint statement on implementation of spontaneous exchange of country-by-country reports on multinationals: US Treasury→

Asia-Pacific

Hong Kong proposes tax cut for insurance-related businesses

The Hong Kong government on December 6 published a bill proposing to reduce . . .

Europe

Ireland updates guidance on FATCA implementation: Irish Tax and Customs→

Americas

France rejects US plan to turn pillar one of tax rewrite into a “safe harbor,” says EU should negotiate digital tax if global agreement falls through: Tom Ozimek / Epoch Times→

Americas

US again delays effective dates of foreign currency tax regulation

The US IRS has announced that it will again delay by one year the effective date . . .

Asia-Pacific

Georgia adopts changes to transfer pricing legislation

December 6, 2019

Gela Barshovi, Tax Advisor and Managing Partner at TPsolutions, Tbilisi, Georgia, discusses December 2 amendments made to Georgia’s transfer pricing laws . . .

Europe

Montenegro joins the Inclusive Framework on BEPS to fight MNE tax avoidance

Montenegro has become the 136th country to join the Inclusive Framework on BEPS, a coalition of countries that have pledged to adopt . . .

Asia-Pacific

South Korea, Cambodia sign tax treaty: The Korea Herald→

Europe

Netherlands publishes first summaries of private tax rulings issued to MNE groups

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands” publication, on October 16, of the first redacted summaries of private tax rulings . . .

Africa

More highlights on Zimbabwe’s proposed 5 percent digital tax

Nyasha Machiri, a Senior Tax Consultant at Baker Tilly Chartered Accountants, discusses the latest information about Zimbabwe’s proposed digital tax . . .

Africa

Is the US about to blow up the OECD’s compromise “pillar one” plan for taxing multinational group profit?

In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECD’s compromise proposal to overhaul the rules for allocating multinational group profit and related taxing. . .

Africa

OECD releases 186 comment letters on proposal for global minimum tax on multinational group profit

The OECD today released 186 comment letters in response to its request for assistance in the design of a global minimum tax on multinational group profit. The OECD also released the, , ,

Asia-Pacific

Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes

The Australian government on November 29 released the synthesized texts of tax . . .

Asia-Pacific

Microsoft settles New Zealand transfer pricing dispute: Paul McBeth / NZ Herald→

Developing countries’ favored formulary approach is superior to OECD proposal which cobbles together parts of incompatible proposals, professor asserts: Sol Picciotto / ICTD→

Belgium

Latest EU effort to make country-by-country reporting public fails

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

US publishes final and proposed base erosion anti-abuse tax regs

The US on December 2 released 343 pages of final and proposed regulations on the base erosion and anti-abuse tax (BEAT). The BEAT, added in the . . .

Americas

US issues final foreign tax credit regulations

The US IRS on December 2 issued comprehensive final and temporary regulations addressing the foreign tax credit. The new regs finalize a . . .

Americas

EU Commission won’t challenge Starbuck’s State aid victory, Vestager says: Lewis Crofts and Nicholas Hirst / MLex Market Insight→