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The governments of Japan and Serbia on November 5 completed the necessary exchange of diplomatic notes for the entry into force of the tax treaty between the two countries that was signed in July 2020 and will generally have effect beginning in . . .

Americas

US corporate minimum tax proposal would likely hit several large companies in tech (Amazon, Google, Intel), telecom (Verizon, Comcast), banking (Morgan Stanley, JPMorgan Chase), and more: Kevin Schaul / Washington Post→

Europe

Romania updates list of large taxpayers required to prepare transfer pricing documentation

Adrian ȚAGA, Romanian National Tax Agency, discusses the agency’s October 29 publication of a new order updating the list of large taxpayers that are required to prepare transfer pricing documentation according to a specific set of criteria that relate to . . .

Americas

Peruvian legislative project would modify tax on nonresident entities’ presumed income

Gonzalo Escalante, Zegarra Aguilar Abogados, discusses the Peruvian prime minister’s October 27 delivery to congress of a legislative project seeking to increase the presumed income applicable to nonresident entities and their branches or other . . .

Africa

Côte d’Ivoire finance bill 2022 will adjust tax on related party transactions

Moïse Gnakouri, Catholic University of Louvain, discusses the Côte d’Ivoire’s 2022 finance bill, unveiled on October 20, which adjusts the taxation of intra-group transactions; it provides that the withholding tax on non-commercial profits and/or value-added tax (VAT) is due as soon as . . .

Asia-Pacific

Jordan publishes executive instructions for transfer pricing rules

Nour Ali, DNV, discusses Jordan’s September 16 release of the country’s latest transfer pricing guidance regarding the disclosure form, local file, master file, and country-by-country report, along with specific . . .

Accounting

Ireland considers new tax measures for outbound payments

November 5, 2021

The Irish Department of Finance on November 5 launched a public consultation on the introduction of new corporate tax rules applicable to outbound payments of interest, royalties, and dividends; the measures would deny . . .

Accounting

FASB accounting update addresses revenue contracts with acquired customers

November 5, 2021

The US Financial Accounting Standards Board (FASB) on October 28 released an accounting standard update with guidance on the accounting of revenue contracts with customers that are acquired in a business combination, which is intended to . . .

Africa

Kenya prefers its digital tax, which hits 89 companies in the country, to global tax deal, which would only hit 11 (exempting Uber and others); also objects, with Nigeria, to deal’s mandatory binding arbitration: Carlos Mureithi / Quartz Africa→

November 5, 2021

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Americas

Global minimum tax will work, if implemented, OECD’s Saint-Amans says

OECD tax policy director Pascal Saint-Amans in a November 4 interview expressed that the political agreement on a 15% global minimum effective tax rate is a big deal, he is very pleased with the outcome, and he has little fear of companies attempting to exploit loopholes to evade the tax because . . .

Americas

Biden administration’s budget bill tax revenue estimates confirmed, partly

The revenue expected to be raised from the tax provisions included in the current draft of the Democrats’ Build Back Better budget is largely in line with the Biden administration’s claims, based on estimates released November 4 by the non-partisan US Congressional . . .

Europe

French transfer pricing case highlights functional analysis at heart of tax litigation

Patrick Donsimoni, La Boetie, discusses the French supreme tax court’s October 4 decision, underlining that a group’s transfer pricing policy must be in line with the structuring of its supply chain since the functional analysis is decisive for . . .

Accounting

US budget bill tax provisions’ effective dates, rates, thresholds

November 3, 2021

Following a November 2 off-year election that many pundits consider an initial bad omen for the Democrats, Biden and the party continue to finalize the details – and secure the votes – for the signature portion of the President’s agenda, including several notable corporate and international tax . . .

Asia-Pacific

Cairn and India to resolve long-running tax dispute

November 3, 2021

On November 3, UK-based Cairn Energy announced that it is engaging with the Indian government, under the provisions of the recent Indian legislation withdrawing a controversial retroactive tax law, to resolve its more than USD 1 billion tax dispute with the country and obtain . . .

Asia-Pacific

Singapore finance minister explains why global tax deal is a ‘challenging development’

In a November 1 reply to a parliamentary question about potential revenue gains under the OECD global tax deal, Singapore’s Minister for Finance Lawrence Wong explained that such estimates are not so simple and, moreover, the agreement presents some challenges for . . .

Accounting

American Institute of CPAs suggests Congress reconsider corporate minimum tax

The corporate minimum tax included in the budget reconciliation bill would create undue complexity and alter financial accounting decision making, according to an October 28 letter from the AICPA to lead congressional tax writers, saying this type of tax . . .

Americas

UK consults on introduction of corporate re-domiciliation regime

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Asia-Pacific

Spanish Supreme Court denies access to MAP in domestic GAAR tax case

Aitor Navarro, Carlos III University, discusses the September 22 Spanish Supreme Court decision regarding SGL Carbon Holding (ECLI:ES:TS:2021:3572), addressing the denial of a mutual agreement procedure (MAP) initiation request on the grounds of tax abuse in a case involving . . .

Europe

Norway proposes important changes to rules on tax-free cross-border reorganizations