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Two weeks to 24 March 2023

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. 

UK

Spring Budget and Finance Bill 2023

Chancellor Jeremy Hunt delivered his Spring Budget on 15 March 2023, which was followed by the publication of the Spring Finance Bill 2023 (aka Finance (No.2) Bill 2023) on 23 March.  

  • Spring Budget 2023 - reactions webcast
    Our panel of tax, economic and political specialists hosted a webcast on 16 March to discuss what the announcements could mean for individuals and businesses. The webcast is available for replay on demand via this link.
  • Links to pdf of bill and explanatory notes.
  • Link to HM Treasury press release.

Visit our dedicated Budget webpage for further insights and commentary. 

Pillar Two
Pillar Two brings unprecedented changes to the global tax system, impacting large multinational companies that operate under the reformed international tax framework.  Legislation relating to the UK implementation of Pillar Two was included in the Spring Finance Bill published on 23 March.  As expected, it includes an Income Inclusion Rule ("IIR") and UK domestic top up tax (“QDMTT”), both of which are scheduled to be introduced for accounting periods beginning on or after 31 December 2023.  It also includes transitional safe harbour provisions.  To understand how it might impact your company, see:

  • PwC publishes Pillar Two Data Input Catalog
    We have published our Pillar Two Data Input Catalog, which highlights the urgency for taxpayers to start preparing for Pillar Two.  It outlines anticipated divergences in Pillar Two rules, calculation complexities, and considerations in developing an extensive data strategy.  Read more.
  • Pillar Two Readiness: Complex data and complex challenges
    In this Cross-border Tax Talks episode from 15 March, Doug McHoney (PwC's US International Tax Services Global Leader) and Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice discuss the Data Input Catalog and the complex data challenges of Pillar Two.

For further information regarding the UK implementation of Pillar Two, see our UK Pillar Two webpage.

Treaty updates

  • Kyrgyzstan tax treaty correction
    The 2017 agreement was previously published as being in force and effective in the UK from 1 January 2023. HMRC has confirmed on their webpage that this was an error as the agreement is not yet in force.

HMRC International Manual update
HMRC has updated section INTM483110 - Transfer pricing: operational guidance: working a transfer pricing case: penalties for additional paragraphs.

PwC webcast: How technology is opening up a world of new possibilities for Tax
Tax teams are seeing the benefit of the latest wave of technological advances, which have the potential to catapult tax to the front of the finance function investment agenda. In our next Delivering Tax webcast, taking place on Wednesday 29 March at 3pm we will touch on cloud, ERP and some of the latest tech we’re introducing along with our alliance partners to deliver outstanding results for tax departments. You can register here.

Collaboration is the key to bridging the capability gap
Adaptable, scalable and agile, managed services could prove to be the winning factor for how business leaders address existing gaps with skills or technology without compromising the need to transform and invest in future strategic needs. Read more in our article.

The transformation imperative
The right balance of talent and technology is critical to delivering transformations people can trust. In this video we explore how to find that balance, why there is a pressing imperative to transform and where organisations should start.

EU

MEPs adopt series of recommendations to fight tax abuse and money laundering
Following months of work, MEPs recently adopted a comprehensive set of recommendations stemming from the lessons learnt from the Pandora papers and other similar data leaks. The report, which is not yet available, calls for continued momentum to enact proposed legislation, more commitment to correctly implement and enforce what has already been agreed, and makes suggestions for a host of new reforms considered essential. Read more in this European Parliament press release.

CFE Tax Advisers Europe

  • EU Tax Policy News Top 5
    The latest round-up of EU Tax Policy news from the Confédération Fiscale Européenne (CFE). The latest edition from 20 March includes: 1) CJEU To Hear Apple State Aid Case in May; 2) EU Parliament Subcommittee on Tax Matters to Discuss Pillar 1 & 2 with OECD; 3) Register Now: CFE Forum – 20 April 2023 – “Towards a More Cohesive European Fiscal Union? Minimum Tax & VAT in the Digital Age”; 4) OECD Public Consultation on Global Minimum Tax; and 5) CFE Opinion Statement on VAT Compensation Payments. Visit their latest news page here.
  • EU Global Tax Top 10 - February edition
    This edition includes: 1) EU list of non-cooperative jurisdictions for tax purposes updated; 2) OECD guidance on minimum tax – Pillar 2; 3) EU summary report on tax enablers (SAFE) consultation; 4) EU Parliament Subcommittee on tax matters publishes 2023 Schedule of Work; 5) Register now: CFE Forum – 20 April 2023 – ‘Towards a More Cohesive European Fiscal Union? Minimum Tax & VAT in the Digital Age’; 6) OECD public consultation on compliance & tax certainty of global minimum tax – 16 March 2023; 7) FATF updates list of jurisdictions under increased AML monitoring; 8) EU Parliament publishes study on tax compliance costs; 9) ECHR publishes Judgment in LuxLeaks Whistleblower case; and 10) UN invites public input on International Tax Plan.

OECD

Pillar Two

  • Public consultation meeting on compliance and tax certainty aspects of global minimum tax
    The OECD held a public consultation meeting on 16 March 2023 to discuss the input provided from the recent Pillar Two consultations: 1) GloBE Information Return; and 2) Tax Certainty for the GloBE Rules. The event was recorded and the replay is available here
  • Germany publishes Pillar Two discussion draft
    The Federal Ministry of Finance has published a draft law to implement the ‘Pillar Two’ Directive. Read more in this PwC Tax Insights.

MLI

  • MLI enters into effect on 1 January 2024 for Mexico
    Mexico recently deposited its instrument of ratification for the Multilateral Instrument (MLI) with the OECD. The MLI will enter into force on 1 July 2023, and will be effective for all Mexican tax purposes on 1 January 2024. Read more in this PwC Tax Insights.
  • Sustained progress demonstrated in the latest OECD peer review results on the prevention of tax treaty shopping
    These peer review results reveal that members of the Inclusive Framework on BEPS are respecting their commitment to implement the minimum standard on treaty shopping and further confirms the importance of the BEPS Multilateral Instrument (MLI) as the tool used by the vast majority of jurisdictions that have started to implement the BEPS Action 6 minimum standard. Read more in this OECD item.

The text of the BEPS Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available at https://oe.cd/mli.

Vietnam joins multilateral tax administrative assistance pact
The Deputy Finance Minister of Vietnam signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on 22 March, bringing the total number of jurisdictions that participate in the Convention to 147. See this OECD item.

Other territories

International
Digital tax byte
The latest edition in our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of digitalisation of business. This edition, from 24 March, includes: 1) comment on the US President’s FY24 Budget Proposal and Treasury’s Green Book and note the US request for feedback on NFT guidance; 2) Germany has published draft legislation for the implementation of Pillar 2; 3) following earlier consultation, the UK has included provisions on the 'multinational top-up tax' and a 'domestic top-up tax' in the Finance Bill 2023; 4) Malaysia's postponement of the imposition of sales tax on low value goods.

Digital tax megabyte for February 2023
This edition, to the end of February, includes: 1) UAE Decision and Public Clarification provide guidance on e-commerce VAT reporting; 2) New Zealand political parties argue about taxing digital platforms; 3) Egypt readies businesses without a presence there for VAT registration; 4) South Africa announces plans for draft rules and consultation on Pillar 2; 5) Hong Kong Budget announces Pillar 2 plans for 2025; 6) Bermuda Budget sets second half of 2023 for proposals on Pillar 2; 7) Argentina to collect VAT from platform economy from 1 April 2023; 8) UAE corporate tax pre-registrations; 9) Singapore Budget announces Pillar 2 plans; 10) Washington amends sourcing regulations clarifying SaaS and digital products; 11) Massachusetts Supreme Court rejects ‘cookie nexus,’ retroactive Wayfair application; 12) Kenya draft ESS update regulations for stakeholder engagement; and 13) DAC7 - EC consultation and webcast.

Environmental, Social and Governance (ESG) 

  • Are you ready for the EPR era?
    A decade ago, the idea of a circular economy was very much an outlier in mainstream business thinking. Not any longer. Circular economy and waste legislation are introducing measures to improve waste management – notably Extended Producer Responsibility (EPR) obligations for different products and waste flows.  In this article, we discuss what EPR is, how it will impact businesses and what they can be doing now to prepare.

For more ESG insights, visit our dedicated ESG webpage.

Australia

Budget consultations

  • Proposed new tax transparency measures for public companies
    The Australian government has released draft legislation to implement a proposed new measure requiring public companies to publicly disclose information about their subsidiaries. If the draft legislation becomes law, Australian public companies (listed and unlisted) would be required to publish a ‘consolidated entity statement’ that contains additional information about their subsidiaries including tax residency, ownership breakdown and entity type. The new measures will apply to financial years commencing on or after 1 July 2023. Read more in this PwC alert.
  • Australia’s proposed new interest limitation regime
    Australia’s Treasury recently released for comment draft law and explanatory materials to implement the Federal Government’s proposed new interest limitation rules that will replace the existing thin capitalisation safe harbour, worldwide gearing and arm’s length debt tests. The draft legislation also included a few surprises in the form of previously unannounced proposed amendments. These new rules will apply for income years commencing on or after 1 July 2023. Read more in this PwC alert. Also see:

30 April R&D Tax Incentive lodgement deadline approaching
Companies with a 30 June 2022 year wishing to register R&D activities must do so by 30 April 2023. If unable to meet this deadline, R&D entities can apply for extensions, which must be done on the R&D portal. Read more in this PwC alert.

Austria
Austrian Federal Tax Code (BAO) – increase of interest rates
Due to the further increase of the key ECB interest rate by 0.5%, changes to deferral interest, interest for suspension, claim interest (interest for subsequent payments and credits), appeal interest, as well as VAT interest have occurred. Read more in this PwC news item.

Belgium

See here for latest updates.

Tax Treaty concluded between Belgium and Luxembourg – new 34-day limit
In August 2021, Belgium and Luxembourg signed an avenant to the tax treaty in order to extend the 24-day limit to 34 days. This avenant makes remote working (slightly) easier for cross-border workers as they can now work an extra 10 days outside of their normal State of employment without triggering an apportionment of the right to levy tax between both countries. The extension to 34 days is now official. The Protocol was published on 20 March 2023 in the Belgian Official Gazette and is applicable as from 1 January 2022. Read more in this PwC news item.

Canada
2023 Ontario budget - tax highlights
Ontario’s Minister of Finance presented the province’s budget on 23 March. The budget does not change corporate or personal income tax rates, but does: 1) introduce the Ontario Made Manufacturing Investment Tax Credit, a refundable tax credit for manufacturing and processing in Ontario; and 2) commit to previously announced measures to improve Ontario’s film and television tax credits. This PwC Tax Insights discusses these and other tax initiatives outlined in the budget.

Denmark
Danish Transfer Pricing Documentation Rules
In 2021, the Danish Tax Agency "Skattestyrelsen" announced a stricter approach to the country’s transfer pricing documentation, introducing mandatory filing and penalties. More than a year has passed since the changes came into effect and for groups with local presence, or operations, in Denmark it is time to review their annual reporting obligation, to avoid being subject to penalties for non-compliance. This PwC article shares the latest news on the Danish transfer pricing rules and how the tax landscape has been affected since they were introduced.

Germany
Germany publishes Pillar Two discussion draft
The Federal Ministry of Finance published a draft law on 20 March to implement the Pillar Two Directive (the so-called Minimum Tax Directive Implementation Act - MinBestRL-UmsG). The implementation of the EU Minimum Tax Directive is provided through a separate law, the Minimum Tax Act (MinStG). Read more in this PwC Tax Insights.

Retroactive effects of over-surrenders from periods prior to tax consolidation in part unconstitutional
The Federal Constitutional Court recently held that the retroactive introduction of Sec. 14 (3) Corporation Tax Act concerning the treatment of over-surrenders arising from periods prior to the membership in an Organschaft (tax consolidation group) to be in part unconstitutional and thus invalid. Read more in this PwC blog.

Findings during cash inspection may warrant subsequent tax audit
Similar to a VAT inspection pursuant to Section 27b of the German VAT Act, the review of the cash-system (in this case at a restaurant business) does not require prior notice or the specification of reasons. This was decided by the Hamburg Tax Court. In addition, the court held that the cash inspection allows an automatic follow-up tax audit if warranted by the facts determined during the cash inspection. Read more in this PwC blog.

India
Receipt of shares in a List Co as a gift without consideration from holding/ group company is not taxable under either section 56(1) or section 28(iv) of the Act
The Mumbai bench of the Income-tax Appellate Tribunal has held that receipt of shares in a listed company by the taxpayer is a capital receipt that is not chargeable to tax under either sections 56(1) or 28(iv) of the Income-tax Act, 1961. Read more in this PwC Tax Insights.

Amount received for allowing access to an online database of journals and books is not taxable as a royalty under the India-USA double tax treaty
The Delhi bench of the Income-tax Appellate Tribunal has held that the amount received for providing access to an online database of books and journals, maintained by the appellant, cannot be categorised as a royalty under Article 12 of the India-USA Double Tax Treaty. The Tribunal observed that by providing access to the online database, the appellant does not transfer any copyright to the customers; rather, it grants only limited rights of access to the database on subscription basis, which cannot be considered as a royalty, in light of the Supreme Court decision in the case of Engineering Analysis Centre of Excellence Private Limited. Read more in this PwC Tax Insights.

Ireland
Investing in Ireland - March 2023 edition
In this issue of our newsletter on foreign direct investment (FDI) in Ireland, we explore the US-Ireland collaborative business relationship in addition to analysis of the increasing trend of investing in regional locations in Ireland and an exploration of Ireland’s sustainability efforts for business.

Tax Facts 2023
Tax Facts 2023 is PwC Ireland’s practical, easy-to-follow guide to the Irish tax system. It includes a summary of Irish tax rates, as well as an outline of the main areas of taxation.

Tax Transparency Report 2023
PwC Ireland’s 2023 Tax Transparency Report sheds light on the tax disclosure trends for Ireland’s listed entities and the implications for voluntary tax disclosures and tax strategies.

Ireland updates FATCA filing guidelines
The Irish Revenue has updated the filing guidelines for the US Foreign Account Tax Compliance Act (FATCA).

Offshore Funds - taxation of income and gains from EU, EEA and OECD member states & from certain offshore states
The Irish Revenue has updated the Tax and Duty Manuals (TDMs) concerning the taxation of Offshore Funds.

Italy
Cross-border conversions, mergers, and demergers
Legislative Decree No. 19 of 2 March 2023 was recently published in the Official Gazette (“Gazzetta Ufficiale No. 56/2023”), containing the rules on “Implementation of the Directive (EU) 2019/2121 of the European Parliament and of the Council of November 27, 2019, amending Directive (EU) 2017/1132 as regards cross-border conversions, mergers, and demergers.” Read more in this PwC blog.

Korea
Korean Tax Update - March 2023
The latest edition includes: 1) Government announces the amended presidential decrees of tax laws and a bill to amend the relevant enforcement rules; 2) MOTIE announces the government’s core mineral resources strategy; 3) National Tax Service and Korea Customs Service sign a memorandum of

understanding to support SME exporters; and 4) Rulings update. 

Luxembourg
Tax Treaty concluded between Belgium and Luxembourg – new 34-day limit
In August 2021, Belgium and Luxembourg signed an avenant to the tax treaty in order to extend the 24-day limit to 34 days. This avenant makes remote working (slightly) easier for cross-border workers as they can now work an extra 10 days outside of their normal State of employment without triggering an apportionment of the right to levy tax between both countries. The extension to 34 days is now official. The Protocol was published on 20 March 2023 in the Belgian Official Gazette and is applicable as from 1 January 2022. Read more in this PwC news item.

Mexico
MLI enters into effect on 1 January 2024 for Mexico
Mexico recently deposited its instrument of ratification for the Multilateral Instrument (MLI) with the OECD. The MLI will enter into force on 1 July 2023, and will be effective for all Mexican tax purposes on 1 January 2024. Read more in this PwC Tax Insights.

Netherlands
Consultation on changes to NL fund tax regimes
The Dutch Ministry of Finance has launched an internet consultation in relation to changes of various Dutch fund tax regimes. The changes include: 1) the disallowance of direct investments in real estate by Dutch Fiscal Investment Institutions (‘fiscale beleggingsinstellingen’); 2) amendments of the conditions for tax transparency for Mutual Funds (‘fonds voor gemene rekening’) and 3) limitation of the Exempt Investment Institutions (‘vrijgestelde beleggingsinstellingen’) to regulated funds. Read more in this PwC alert.

New Zealand
Tax Policy Bulletin - March 2023
Tax Policy Bulletin is our monthly round-up of key recent tax headline news items from New Zealand. This edition covers: 1) Tax Bill reported back; 2) Update on the "Apps Tax"; 3) Government announces Fringe Benefit Tax exemption for bikes and scooters; 4) Tax relief for businesses impacted by flooding and cyclones; 5) Opposition Finance Spokesperson discusses National Party's tax policy agenda; 6) Round-up of open consultations, recent tax cases, and Inland Revenue guidance.

Romania
New CbCR requirements for groups with an establishment in Romania
The Romanian Government recently formally introduced the EU public country-by-country (CbC) requirements, transposing into the national legislation the provisions of EU Directive 2021/2101. The new legislation is effective starting 1 January 2023 and applies to financial years beginning on or after 1 January  2023 (which is earlier than the 22 June  2024 deadline set by the EU Directive). Following these amendments, Romania becomes the first EU Member State to officially introduce public CbC reporting obligations, with a deadline for the CbC preparation and public disclosure significantly earlier than that set by the EU Directive. Read more in this PwC blog.

South Africa
Tax Synopsis - February 2023
This edition includes: 1) Primary operations of a business: Am I who I decide to be, or am I simply what I’m authorised to be? The case of SARS v Coronation; 2) A recent High Court judgment reiterates that SARS bears the onus of proof in the context of understatement penalties; 3) Considering the effect of SARS’ intended withdrawal of Practice Note 31 for taxpayers; and 4) SARS watch.

Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.

US
Budget 2024
The White House released President Biden’s Fiscal Year 2024 Budget (‘FY24 Budget’) on 9 March. On the same day, the US Treasury released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals, commonly referred to as the ‘Green Book.’

  • Treasury releases ‘FY24 Green Book’ describing Biden’s tax proposals for businesses
    The FY24 Budget proposes to raise the corporate tax rate from 21% to 28%, raise the GILTI rate from 10.5% to 21%, and quadruple the tax on corporate stock buybacks from 1% to 4%. Also included in President Biden’s budget is unspecified ‘additional support’ for R&E expenditures. The proposal to replace the BEAT with a UTPR and a domestic minimum top-up tax is perhaps the most significant US international tax proposal in the FY24 Budget. The UTPR proposal attempts to align the US rules for foreign-parented MNCs with the OECD’s Pillar Two Model Rules, including setting the tax rate at 15% and using modified financial accounting concepts (including modified deferred taxes) to determine the amount of tax paid in a jurisdiction. Read more in this PwC Tax insights.
  • Bipartisan R&D bill may lead to broader tax legislation
    In this Policy in Demand episode from 20 March, Rohit Kumar discusses how banking sector concerns likely will not affect the discussion on Capitol Hill around legislation and the debt limit, the key global and domestic tax issues raised at the recent Senate Finance Committee hearing on President Biden's budget, and how introduction of a bipartisan R&D bill may lead to broader tax legislation.
  • Budget likely will not affect debt limit discussions
    In this Policy in Demand episode from 13 March, Pat Brown discusses how the budget likely will not affect debt limit discussions or move the US closer to Pillar Two alignment as he sees few areas of potential bipartisan consensus.

Pillar Two

  • Pillar Two Readiness: Complex data and complex challenges
    In this Cross-border Tax Talks episode from 15 March, Doug McHoney (PwC's US International Tax Services Global Leader) and Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice discuss the Data Input Catalog and the complex data challenges of Pillar Two. 

Helpful IRS guidance regarding midyear PTEP distributions
The IRS’s Office of Chief Counsel recently released an Advice Memorandum that addresses the interplay between CFC, Subpart F income, and GILTI. Read more in this PwC Tax Insights.

FASB issues Exposure Draft for proposed changes to income tax disclosures
The Financial Accounting Standards Board (FASB) recently issued an Exposure Draft (ED) of a proposed Accounting Standards Update (ASU). The proposed ASU represents the FASB’s ongoing efforts to enhance the transparency and decision usefulness of annual and interim income tax disclosures. These proposed changes would apply to all entities that are subject to income taxes, with certain of the proposed amendments being applicable only to public business entities. Comments from respondents are due to the FASB by 30 May 2023. This PwC Tax Insights highlights the proposed amendments to income tax disclosures, which generally impact a company’s rate reconciliation and income taxes paid disclosures, as well as other considerations. See also:

  • Policy on Demand: FASB exposure draft: Key for companies to engage and prepare
    In this episode from 21 March, Jenn Spang discusses key proposed changes, when they may be finalised and become effective, and how companies should engage through the comment process and prepare for the impact of the changes.

Treasury and IRS issue guidance on whether certain NFTs are Section 408(m) collectibles
The Treasury Department and the IRS have released Notice 2023-27, signalling their intent to issue guidance on the treatment of certain non fungible tokens (NFTs) as Section 408(m) collectibles and providing interim guidance on characterisation until additional guidance is issued. Treasury and the IRS are also requesting comments by 19 June 2023, regarding a variety of questions on the characterisation of NFTs. Read more in this PwC Tax Insights.

Interim tax accounting considerations for recent legislative and global developments
As companies begin to focus on financial reporting in 2023, there are multiple variables to evaluate and assess. Concerns over the health of the US and global economy, elevated inflation, rising interest rates and geopolitical pressures may result in companies facing strong headwinds in forecasting profitability for 2023 and possibly beyond. This PwC Tax Insight highlights key areas of focus for interim reporting periods, including an overview of the fundamental framework, as well as an update on key global legislative developments.

Policy on Demand series - Week in Review 

  • In this episode from 24 March, Mark Prater discusses how recent Treasury guidance on tax incentives included in the CHIPS Act and the Inflation Reduction Act is intended to provide taxpayers with needed clarity before they commit to investments. Legislative hurdles likely will delay any reversal of Section 174 R&D amortisation. Mark encourages companies to focus on efforts to address Section 174 and provide additional guidance on climate and CHIPS provisions.
  • In this episode from 17 March, Karl Russo discusses how unexpected developments can disrupt the markets and change the agenda of policy makers. US multinationals continue to be concerned about how they may be affected by President Biden’s budget’s attempt to align the US with Pillar Two. Karl encourages companies to monitor how recent developments in the banking sector could affect discussions around interest rates and the debt limit.

Tax Readiness webcast series

  • Tax Readiness: Demystifying the data dilemma - How tax can stay ahead of constant change
    Consistent, reliable data is the pinnacle of success and a critical component in building operational readiness in tax. It can help manage reporting obligations, alleviate internal and external demands, and serve as the cornerstone of compliance and implementation for required changes (eg Pillar Two). Join our panel of specialists on Tuesday 18 April at 7pm for a “how to” discussion on realising a future-ready, data-driven tax function powered by a new baseline of capabilities. Register here.
  • Tax Readiness: Q1 Financial reporting considerations
    Register here to join our panel of PwC specialists on Tuesday 28 March at 8pm as they take a deep dive into key tax accounting and reporting reminders and discuss recent tax developments.
  • Tax Readiness: Deals Outlook - The tax perspective
    In this webcast from 2 March, our panel reviews the recently launched US Deals 2023 outlook and discusses key tax issues and opportunities including the new stock buyback excise tax, divestitures, expiring provisions, and state and local taxes. Watch the replay here.

State and local tax

  • Florida court requires cost of performance method for sourcing service income
    A Florida circuit court recently ruled that the sourcing of service income requires application of a cost of performance methodology. Read more in this PwC Tax Insights.
  • Texas amends service sourcing rule to rely on location of personnel or equipment
    Texas generally sources revenue from services to the location where the service was performed.  On 25 March The Comptroller amended its Texas Margin rule to replace its “receipt producing, end-product act” test with a focus on the location of a taxpayer's personnel or equipment is physically doing useful work for the customer. However, the amendments do not include changes to internet hosting services or internet advertising provisions adopted by the Comptroller on 15 January 2021. Read more in this PwC Tax Insights.
  • Tax Readiness: 5 years later - The impact of Wayfair and tax reform on state taxation
    It has been almost five years since the US Supreme Court decided South Dakota v. Wayfair and struck down the long standing “physical presence” nexus test, and a little more than five years since the Tax Cuts and Jobs Act rewrote the federal income tax laws for the first time since 1986. Register here to join our panellists on Tuesday 25 April at 7pm as they discuss the evolving compliance challenges produced by these two events and how companies are implementing leading practices to reduce costs, minimise risk, and produce cash tax savings.

Further information
You and your clients can sign up for Tax Alerts issued by the US to be emailed to you. Subscribe using the link on this pageA back catalogue of previous webcasts and other resources are available on our US tax reform hub here.  

Vietnam
Vietnam joins multilateral tax administrative assistance pact
The Deputy Finance Minister of Vietnam signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on 22 March, bringing the total number of jurisdictions that participate in the Convention to 147. See this OECD item.