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Digital Economy

Italy still plans to implement 3 percent “web tax” on large digital firms in 2020, minister says: Giuseppe Fonte / Reuters→

Europe

Guernsey sets out additional information required on tax return to establish economic substance: States of Guernsey Revenue Service→

Digital Economy

German legislation imposing VAT liability on online platforms is contrary to EU law, Commission asserts

The EU Commission on October 9 asked Germany to withdraw VAT changes . . .

Carbon Tax

IMF says immediate global carbon tax needed to prevent climate change: International Monetary Fund→

Africa

African countries support OECD pillar one unified approach with carve-out for commodities and extractives, Amount B fixed minimum remuneration: African Tax Administration Forum→

Asia-Pacific

Australia defers expansion of reportable tax position filing to large private companies until 2020-21 financial year: Australian Taxation Office→

Americas

US IRS addresses expiration of temporary section 385 debt/equity regs

The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation . . .

Americas

Cayman Islands to introduce public register of beneficial ownership: Cayman Islands→

October 11, 2019

Americas

Bipartisan US Senate bill would require reporting on beneficial ownership information: Joseph Moreno / Cadwalader Cabinet→

October 11, 2019

Americas

US IRS issues 2019-2020 priority guidance plan: US Department of Treasury→

Africa

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

Davide Anghileri of the University of Lausanne, Switzerland, resolutions relating to taxation adopted by the of the EU Council today . . .

Digital Economy

OECD’s proposed “unified approach” would give market countries greater taxing rights over large multinationals that sell to consumers

In an effort to expedite agreement between nations on an update to the international tax rules to account for new digital business models, the OECD secretariat on October 9 proposed a compromise plan for allocating multinational . . .

Europe

Ireland Budget 2020 released

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Budget 2020 measures, released by the government on October 8 . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Africa

Angola: VAT introduced October 1 replacing consumption tax: Macauhub→

October 8, 2019

Africa

EU Code of Conduct Group proposes changes to tax blacklist for seven countries including Switzerland, UAE, Mauritius

October 8, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses October 4 EU Code of Conduct Group (Business Taxation) recommendations for amendments to the EU list of non-cooperative tax jurisdictions . . .

Americas

Argentina issues burdensome draft transfer pricing guidance for public comment

Elisa Kaminsky, a senior associate at BaseFirma, Miami, discusses an October 2 public consultation on new Argentina transfer pricing guidance which includes significant and burdensome new requirements . . .

Asia-Pacific

Australian Taxation Office seeking full bench appeal of Glencore transfer price decision: Tom McIlroy / Financial Review→

Digital Economy

Allocation of greater taxing rights to both location of employment and sales is preferable to OECD pillar one approach, which harms low-income countries, writer say: Alex Cobham, Tommaso Faccio, Valpy FitzGerald→

Europe

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty

Leopoldo Parada of the University of Turin, Italy, writes about the implications of the EU General Court’s decsion in the Fiat and Starbucks state aid cases . . .

Digital Economy

Italy probing whether infrastructure used by Netflix constitutes a PE: Stuart Thomson / Digital TV Europe→

October 3, 2019

Europe

EU should be ready to act if no digital tax deal is struck by the end of 2020, incoming EU Commissioners say: EU Reporter→

Denmark

Denmark joins BEPS multilateral instrument

Denmark on September 30 deposited with the OECD its instrument of acceptance . . .

Europe

Jim Harra appointed interim chief of UK tax agency: Beckie Smith / Civil Service World→

Americas

Return on assets (ROA) is an unreliable profit indicator

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that selection of “return on assets” as a profit indicator in transfer pricing can lead to intractable controversy because the term is ill-defined whereas operating profit margin and operating profit markup are more reliable . . .

Americas

Canada’s liberal party proposes three percent digital services tax on advertising, intermediation

Canadian Prime Minister Justin Trudeau’s Liberal Party has proposed in its reelection platform . . .

Draft “toolkit” aims to help developing countries with transfer pricing documentation