Latest

French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires . .

Africa

Zimbabwe proposes amendments to thin capitalization rules

Walker Nyachowe, Managing Director of Walker Consulting Services, discusses Zimbabwe’s Minister of Finance Economic Development’s 2019 Mid-Term Fiscal Policy Review Statement, delivered August 1, which includes proposed amendments the thin capitalization rules . . .

Asia-Pacific

Singapore tax authority publishes etax guide titled “GST: Taxing imported services by way of an overseas vendor registration regime”: Inland Revenue Authority of Singapore→

Asia-Pacific

Norway disallows Telenor losses claimed upon settlement Indian subsidiary’s bank guarantees: Reuters→

Asia-Pacific

Kyocera pays ¥300 m (USD 2.8m) back taxes for not declaring income Singapore subsidiary income: Jiji Press / The Japan News→

Americas

NJ says GILTI, FDII added to general business income apportionment factor, sourced as “other business receipts”: Stephen P. Kranz & Kathleen M. Quinn / Inside SALT→

Americas

US to raise existing tariffs on Chinese goods from 25% to 30% from Oct. 1; raise tariffs set for Sept. 1 from 10% to 15% in retaliation for Chinese tarrifs: Jacob Pramuk / CNBC→

Bulgaria

Bulgarian mandatory transfer pricing documentation rules enacted

August 23, 2019

Ekaterina Aleksova, Senior Manager at PricewaterhouseCoopers Bulgaria discusses a new law introducing mandatory transfer pricing documentation in Bulgaria which was officially published in early August . . .

Americas

China announces new tariffs of 5–10 percent on $75 billion worth of US goods, resumption of auto tariffs: Yum Li / CNBC→

August 23, 2019

Africa

Google warns Kenya lawmakers that digital tax could provoke US trade war: Lynet Igadwah / Business Daily→

August 22, 2019

Americas

Cayman Islands publishes FAQ’s on economic substance for tax purposes

August 21, 2019

he Cayman Islands has published a set of frequently asked questions detailing a law requiring that companies with . . .

CIAT

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss a recent Inter-American Center of Tax Administrations (CIAT) transfer pricing publication which proposes two measures for clarifying the application of the best method rule and thereby preventing the overuse of the transactional net margin method. . .

Europe

Malta publishes patent box rules for IP consistent with qualified nexus approach: Malta Institute of Taxation→

Americas

Discussion of France and UK digital tax expected to dominate G7 finance ministers meeting: France 24→

Asia-Pacific

New Zealand government special report addresses GST on low-value imported goods: Policy and Strategy, Inland Revenue→

Americas

UK must scrap DST for US to negotiate trade deal, US officials warn: Ben Riley-Smith / The Telegraph→

August 6, 2019

Americas

Google, Facebook, Amazon argue at US hearing that French digital tax unfairly targets US companies: Emily Birnbaum / The Hill→

Europe

UK and Gibraltar commence tax treaty negotiations: Vox→

Americas

Apple’s appeal in USD 14.4 b EU State Aid dispute over Irish tax ruling to be heard by EU General Court in September: Stephanie Bodoni / Bloomberg→

Asia-Pacific

China’s planned Shanghai free trade zone to feature 15 percent income tax rate for qualified business: Xinhua→

August 6, 2019

Asia-Pacific

Singapore, Ukraine tax treaty protocol signed to upgrade information sharing

Singapore and Ukraine have signed a tax treaty protocol amending their . . .

Americas

US Senate ratifies protocols to tax treaties with Japan, Switzerland, Luxembourg

The US Senate today ratified protocols to the US’s tax treaties with Japan, Switzerland, and Luxembourg. This follows the Senate ratification on . . .

Americas

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

August 17, 2019

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary to . . .

Multinational

Professor argues that OECD Model’s new “saving clause” conflicts with Article 23 entitlement to double tax relief: Leopoldo Parada / SSRN→

July 10, 2019

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Europe

UK investigating taxes paid by Candy Crush owner, Activision Blizzard, over royalties paid to Malta and Bermuda: Jon Ungoed-Thomas & Lucy Bacon / The Times→

August 5, 2019

Americas

CIAT develops risk model for selection of transfer pricing audit cases in Ecuador: CIAT (in Spanish)→

August 5, 2019

Multinational

Saint-Amans says he “wouldn’t be surprised” if countries agreed to a minimum tax rate of about 12.5 percent in “pillar 2” digital tax revisions: Cliff Taylor / The Irish Times→

July 29, 2019

Americas

Chile government introduces significant changes to tax reform package

July 10, 2019

Francisco Sepúlveda of RGS Abogados, Santiago de Chile, analyzes the latest changes to Chile’s comprehensive tax reform package, which include further regulation regarding digital services, new profit distribution rules, and a new definition of taxable expense . . .

Americas

Google, Facebook, Amazon to testify at US trade hearing on French DST: Reuters→

August 14, 2019

Transfer pricing planning for oil refining, paper and pulp, and other continuous process industries

July 26, 2019

Gaurav Jain and Priya Mani Bhutani discuss transfer pricing issues associated with continuous process industries . . .

Africa

Kenya, Turkey to sign tax treaty: Xinhua→