22/04/2022
Kyrgyzstan, Slovak Republic agree on draft of income tax treaty: AKIpress→ https://buff.ly/38Xxjkm For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: https://buff.ly/2GtxQGP
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Multinational tax and transfer pricing news
22/04/2022
Singapore Telecommunications (Singtel) has filed an appeal after Australian court ruled its subsidiary must pay an AUD 393 million tax bill that leads back to the company’s acquisition of Optus in 2001: The Edge Markets→ https://buff.ly/3v311go For more international tax and transfer pricing news→ https://buff.ly/3rU3d5L
22/04/2022
Francisco Arballo, Grupo Consultor EFE, discusses Paraguay’s publication of rules for preparing local transfer pricing technical study report, sets deadline — MNE Tax — https://buff.ly/3rHBZl3
21/04/2022
Belize and Cameroon deposit instruments of ratification for BEPS MLI with the OECD; entry into force is August 1, for both countries; Japan extends the application of the multilateral BEPS convention: OECD→ https://buff.ly/3LkExxr For the latest tax and transfer pricing news read MNE Tax→ https://buff.ly/2Iy5xcr
21/04/2022
Catch up with MNE Tax: OECD tax plan's unexpected costs I Brazil's new TP regime I ECJ on DAC6, PE I new Belgian anti-tax evasion measure→ https://buff.ly/3uYyloR Never miss the news. Sign up to have MNE Tax delivered to your inbox→ https://buff.ly/2GtxQGP
21/04/2022
US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→ https://buff.ly/3xJ9mb6 For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: https://buff.ly/2GtxQGP
21/04/2022
Alex M. Parker, Capitol Counsel LLC, discusses why muddled goals, broad scope lead to unexpected costs of OECD tax agreement — MNE Tax — https://buff.ly/37yDxqG
20/04/2022
Nigeria, Kenya, Pakistan and Sri Lanka opt out of OECD global tax deal, citing economic impact, report says: Ndubuisi Francis / This Day→ h ttps://buff.ly/3MkGEBq For more international tax and transfer pricing news→https://buff.ly/3rU3d5L
20/04/2022
Nathalie Valluis, French tax lawyer, discusses how changes in Belgian tools to fight tax evasion are impacting French financial institutions — MNE Tax — https://buff.ly/3jWqFgD
20/04/2022
Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss the ECJ AG’s opinion on issues relating to protection of legal privilege in the context of exchange of information obligations under DAC6 — MNE Tax — https://buff.ly/3KXwxlv
20/04/2022
Assistant Secretary for Tax Policy Lily Batchelder says Biden Administration is optimistic that the US will enact Pillar Two in 2022; global corporate tax would stabilize international tax landscape, make it fairer for US workers and businesses: Lily Batchelder / US Department of the Treasury→ https://buff.ly/37saoxi MNE Tax links: https://buff.ly/2xz9x8O
19/04/2022
Adrian ȚAGA, Romania’s National Tax Agency, discusses CJEU ruling on intragroup transaction concerning VAT concept of permanent establishment — MNE Tax — https://buff.ly/3uSHnUj
18/04/2022
Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→ https://buff.ly/3OdH3r3 Read the latest tax news at MNE Tax→ https://buff.ly/3rU3d5L
18/04/2022
OECD seeks public comments by April 29 on extractives exclusion under Amount A of Pillar One. The extractives exclusion will exclude from the scope of Amount A the profits from extractive activities: OECD→ https://buff.ly/3KOpyLJ For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: https://buff.ly/2GtxQGP
18/04/2022
OECD unveils stage 2 peer review assessments under BEPS Action 14 regarding mutual agreement procedure (MAP) for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau, Morocco and Tunisia: OECD→ https://buff.ly/3EdWRFu For the latest tax and transfer pricing news read MNE Tax→ https://buff.ly/2Iy5xcr
18/04/2022
Patrick Donsimoni, La Boetie, discusses characterization as a resident for withholding tax exemption under tax treaties signed by France — MNE Tax — https://buff.ly/36hse5C
14/04/2022
Francisco Lisboa Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the details of Brazil's new transfer pricing regime — MNE Tax — https://buff.ly/3uGfcI4
14/04/2022
Catch up with MNE Tax: US budget I Singtel I Estonian TP I Norway v. ConocoPhillips, Exxon I Bahrain corporate tax I Decriminalizing ma*****na I US SEC v. Amazon→ https://buff.ly/3uFVsnW Never miss the news. Sign up to have MNE Tax delivered to your inbox→ https://buff.ly/2GtxQGP
14/04/2022
New IMF Fiscal Monitor: Chapter 2: Coordinating Taxation Across Borders report says a large portion of MNEs’ profit (representing 9.2 percent of global GDP) reflects excess profit (potentially reaching 60 percent of that total profit), which is efficient to tax because it does not distort investment decisions: International Monetary Fund→ https://buff.ly/3KIuHF3 Read the latest tax news at MNE Tax→https://buff.ly/3rU3d5L
14/04/2022
Kyle Pomerleau, American Enterprise Institute, warns US President Biden’s tax reforms could leave US multinational corporations at a competitive disadvantage — MNE Tax — https://buff.ly/37lbESG
12/04/2022
Annemarie Wilmore, Johnson Winter & Slattery, discusses interest on inbound financing: is it arm’s length? — MNE Tax — https://buff.ly/3O5wndS
12/04/2022
Ricardo Sergio Schmitz Filho, Mykolas Romeris University, discusses Estonia's recent transfer pricing changes, which leave open questions — MNE Tax — https://buff.ly/3O67Hly
12/04/2022
Ireland revises guidance on mandatory disclosure of reportable cross-border arrangements (DAC6) to reflect changes introduced in Finance Act 2021 and to provide additional guidance on various hallmarks, filing obligations, nexus, and the main benefit test: Irish Revenue→ https://buff.ly/37G3Wme Never miss the news. Sign up to have MNE Tax delivered to your inbox→ https://buff.ly/2GtxQGP
11/04/2022
New York City Economist Dr. J. Harold McClure analyzes Norway’s challenge to intercompany loan margins for ConocoPhillips and Exxon — MNE Tax — https://buff.ly/3xreekG
11/04/2022
Raman Ohri, Keypoint, discusses why it’s only a matter of time until Bahrain implements a corporate income tax, which will inevitably be followed by transfer pricing rules — MNE Tax — https://buff.ly/38MaIYd
11/04/2022
US Senate Finance Committee Chair Ron Wyden and Senate Finance Committee Member Rob Portman release bipartisan bill to disallow foreign tax credits for companies that pay taxes to Russia, other tax benefits: United States Senate Committee on Finance→ https://buff.ly/3xfzBW7 For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: https://buff.ly/2GtxQGP
08/04/2022
Allen Tobin, CrossBorder Solutions, discusses what the Ma*****na Opportunity Reinvestment and Expungement Act means for the R&D tax credit — MNE Tax — https://buff.ly/3v1EI9V
07/04/2022
Catch up with MNE Tax: Danish Maersk/Total case I Australian Federal Court rules on privilege I Peru's profit-sharing association contracts I TP update around the world→ https://buff.ly/3KjEL7r Never miss the news. Sign up to have MNE Tax delivered to your inbox→ https://buff.ly/2GtxQGP
07/04/2022
Gonzalo Escalante, Zegarra Aguilar Abogados, discusses Peru's tax law change regarding profit-sharing association contracts — MNE Tax — https://buff.ly/3KjXJun
07/04/2022
Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, analyzes Danish High Court's rejection of discretionary tax assessment in groundbreaking transfer pricing case — MNE Tax — https://buff.ly/3r6UeA8
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