Latest

The tax treaty between Singapore and Brazil, signed in May 2018, entered into force on December 1 and will become effective in January 2022 . . .

Estonia

Estonia’s support for OECD tax deal is conditioned on ensuring that EU implementing rules affect only large in-scope multinationals and ‘leave the rest of our existing system untouched,’ Finance Minister says: Estonian government→

Americas

US-Turkey competent authority agreement on exchange of country-by-country reports signed on November 24: US Internal Revenue Service→

Europe

Dutch committee presents report on conduit companies and associated tax policy options

Jian-Cheng Ku, Gabriël van Gelder and Rhys Bane, DLA Piper Nederland N.V., discuss a Dutch government committee’s November 22 findings on the presence of conduit companies in the Netherlands and what tax and non-tax measures should be taken against . . .

Europe

UK updates slew of tax initiatives, including R&D, transfer pricing, MDR

November 30, 2021

The UK government on November 30, in a planned “Tax Administration and Maintenance Day,” outlined updates to numerous tax policy plans, including measures relating to research and development (R&D) tax reliefs, transfer pricing documentation, mandatory disclosure rules (MDR) . . .

Americas

Canada and Alta Energy tax dispute: treaty shopping or valuation under restructuring

November 30, 2021

New York City Economist Dr. J. Harold McClure analyzes the Supreme Court of Canada’s November 26 decision upholding a taxpayer-favorable ruling in The Queen v. Alta Energy Luxembourg S.A.R.L., in which the legal issue revolved around charges of treaty shopping, but the appropriate valuation of . . .

Accounting

FASB proposes amended disclosures relating to credit losses

The US Financial Accounting Standards Board (FASB) aims to expand information on certain loan refinancings, restructurings, and write-offs through a proposed Accounting Standard Update released on November 23 . . .

Africa

Kenya proposes requiring multinationals with revenues exceeding KES 2.5 billion (USD 22 million) to disclose country-by-country information beginning in January in bid to tackle tax avoidance: Allan Odhiambo / Nation→

Americas

India and US agree on transition from India’s ‘equalization levy’ digital tax

The US and India have reached a compromise on a transition from India’s “equalization levy” digital services tax towards the terms of the October 8 multilateral agreement on new international taxing rules, according to a November 24 . . .

Multinational

Global minimum tax’s potential to put a floor on tax competition hinges on technical issue of how substance-based carve-out is incorporated into ‘effective tax rate’ definition: Michael P. Devereux / Centre for Business Taxation→

Europe

Polish Deal introduces further domestic measures to limit profit shifting

Dr. Monika Laskowska, Warsaw School of Economics, discusses newly proposed amendments to the corporate income tax law set out in the “Polish Deal,” signed into law November 15, introducing several domestic measures that impact intragroup transactions beyond transfer pricing . . .

Morocco finance bill 2022 on track to be adopted with corporate tax changes

Mourad Chatar, Value Square, and Ismail El Koundi, Prokonect Consulting, discuss the November 13 approval by Morocco’s upper chamber of parliament of finance bill 2022, including a plan to replace the progressive corporate income tax with . . .

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Asia-Pacific

Turkey and US agree on phase-out of digital tax

The US Treasury announced on November 22 that it has reached an agreement with the Turkish government on Turkey’s transition from its digital services tax to the new taxing rules under the . . .

Americas

US Congress should cap value of corporate tax incentives – if concern is excessive use of such incentives to avoid tax – rather than creating new, problematic tax on book income: Howard Gleckman / Tax Policy Center→

Europe

Swiss federal act on implementation of international tax agreements: ready for January 2022

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the Swiss Federal Council’s November 10 introduction of the federal act on the implementation of international tax agreements (ITAIA), applicable from 1 January 2022, that aims to update . . .

Europe

EU tax competition driven by R&D and other incentives, not just rates

Tax incentives for research and development (R&D) have narrowed corporate tax bases in EU countries and could be considered “a novel corporate tax competition driver,” according to a November 22 EU Tax Observatory report on new forms of . . .

Accounting

FASB accounting standard update requires disclosure of government assistance

The US Financial Accounting Standards Board (FASB) on November 17 released an accounting standard update to require business entities to include information about certain types of government assistance that they receive in an annual disclosure in . . .

Europe

Dutch 2022 budget approved by House of Representatives, moves to Senate

Jian-Cheng Ku and Rhys Bane, DLA Piper Nederland N.V., discuss the November 11 Dutch House of Representatives’ approval of the government’s 2022 tax plan, including proposals to limit unilateral downward transfer pricing adjustments, implement the last leg of hybrid mismatch rules prescribed by . . .

Belgium

Belgian tax authority clarifies new rule on deduction of foreign business losses

Moïse Gnakouri, Catholic University of Louvain, discusses the Belgian tax authority’s November 3 circular that provides a detailed commentary on new provisions in the Belgian income tax code regarding the deductibility of foreign business losses, which entered into force on . . .

Asia-Pacific

Turkey’s new law amends taxation system: change is the only constant

Oytun Canyas and Bengisu İncikli, CETINKAYA, discuss a new Turkish law that took effect October 26 and includes numerous amendments to the country’s corporate income tax, tax procedure, VAT, stamp tax, and special consumption tax, among other . . .

Americas

US corporate and global minimum tax measures clear House, debate moves to Senate

The US House of Representatives today approved a modified version of President Biden’s Build Back Better bill – including corporate and international tax changes – following protracted debates on the revenue and economic impacts of the provisions; the Senate will take up the bill sometime after . . .

Asia-Pacific

Australian Taxation Office delays year-end country-by-country reporting deadline

Companies facing a December 31 due date for country-by-country reporting obligations will now have until February 4, 2022, to file the reports, according to a November 18 announcement from the Australian Taxation Office, which said it is granting the extra time due to both the . . .

Europe

Isle of Man and Ireland signed tax treaty protocol November 19, underling countries’ commitments to ‘latest international standards in respect of Base Erosion and Profit Shifting’: Isle of Man government→

Europe

CJEU confirms Spanish tax measure for goodwill is unlawful state aid

Ana Garutti, Orange Spain, discusses the October 6 decision of the Court of Justice of the European Union (CJEU) holding that Spain’s aid for investments in foreign entities, through a measure allowing amortization of goodwill, is discriminatory, because the aid . . .

Asia-Pacific

Indian court extends tax exemption of Abu Dhabi Investment Authority to its Jersey trust