Two weeks to 8 December 2023
Welcome to our final 2023 update on recent developments in international and treasury tax of interest to multinationals operating in the UK. We will return in 2024!
Autumn Finance Bill 2023-24
The Autumn Finance Bill 2023-24 had its first reading on 27 November and was published on 29 November. The second reading is scheduled for 13 December. Read more in this press release.
Re-domiciliation - expert panel convened to advise on framework
The Prime Minister unveiled £29.5bn of investment at a historic Global Investment Summit on 27 November and one of the measures he announced was that the Department for Business & Trade had convened an expert panel, chaired by Professor Vanessa Knapp, to explore options for a UK corporate re-domiciliation regime to make it easier for foreign companies to relocate to the UK. The panel will be made up of top financial and legal professionals, and will provide independent, non-binding advice to the government on how best to establish a UK corporate re-domiciliation framework. Read the PM’s full announcement here and this supporting item on the UK government’s website with more information.
HMRC Manual & guidance updates
The following changes have recently been made by HMRC following review:
- International Manual
INTM180020: Foreign entity classification for UK tax purposes: How HMRC arrives at a general view of foreign entities. The page was updated on 5 December to provide details on how HMRC reach a general view on foreign entities, including factors considered.
- Company Taxation Manual
CTM82030 - Corporation Tax: Group relief for carried-forward losses: Restrictions has been updated to provide clarification on application of s188BE.
- Corporate Finance Manual
CFM98750 - Interest restriction: administration: enquiry procedure: extended time limits where there is a discovery - the 3rd paragraph was updated on 29 November.
- International Exchange of Information Manual
- IEIM400080 - Background: Common Reporting Standard - the URL was updated on 27 November
- IEIM400090 - Common Reporting Standard: Participating Jurisdictions - the URL was updated on 27 November
- IEIM300050 - Country-by-Country reporting: The filing obligation - the page was updated on 28 November to insert a URL
- INTM450000: Transfer pricing records: contents - a new page/section was inserted on 6 December.
- Tell HMRC about unpaid tax on cryptoassets
HMRC has issued new guidance on making a voluntary disclosure of any unpaid tax if you have income or gains from cryptoassets, including exchange tokens, NFT’s and utility tokens.
- 2023 UK-New Zealand Memorandum of Arrangement
The 2023 UK-New Zealand Memorandum of Arrangement was added to this HMRC page on 30 November. The Memorandum of Arrangement (MOA) entered into force on 11 October 2023. It is effective in both countries from 11 October 2023.
- 2022 UK-Luxembourg Double Taxation Convention and Protocol
The UK-Luxembourg Double Taxation Convention and Protocol was signed on 7 June 2022 and entered into force on 22 November 2023, with some of the provisions becoming effective on 1 Jan 2024. The details have been added to this HMRC page.
- 2023 UK-San Marino Double Taxation Convention — in force
The Double Taxation Convention was signed in London on 17 May 2023. It entered into force on 30 November 2023 and has been added to the HMRC page here.
- Double Taxation Treaty Passport Scheme register
HMRC has updated the register of overseas corporate lenders who are passport holders for Double Taxation Relief on UK loan interest. The register has been updated as of 5 December with 153 additions, 21 amendments and 137 removals.
The Total Tax Contribution (TTC) of the 100 Group for 2022/23
Now in its 19th year, the annual survey collects data from 100 Group members and reports on the contribution made in taxes borne, taxes collected and the wider economic contribution. Read more.
CJEU annuls EC decision that concluded Luxembourg tax rulings granted to the Engie Group were State Aid
On 5 December 2023, the Grand Chamber of the Court of the Justice of the European Union rendered its judgment in the joined cases C-451/21 P and C-454/21 P regarding the appeals brought by Luxembourg and the Engie group companies against the judgments of the General Court of the European Union (“GC”) of 12 May 2021 (T-516/18 and T-525/18) that previously confirmed the existence of State aid under article 107 TFEU. The CJEU ruled that the European Commission (“EC”) erred in its State aid analysis of the tax rulings granted to the Engie group. Read more in our PwC EUDTG alert.
European Union regulations beyond CSRD
The European Green Deal is a package of policy initiatives introduced by the European Commission (EC) in December 2019. Many companies are already focused on one aspect of the Green Deal - the Corporate Sustainability Reporting Directive (CSRD). But the CSRD is far from the only European Union (EU) regulation needing immediate attention. This PwC publication details several other pressing and broadly applicable EU regulations that would also be newly applicable - or possibly already applicable - for both EU and non-EU companies.
Economic and Financial Affairs Council, 8 December 2023
The latest ECOFIN Council meeting took place on 8 December. The main results of the meeting are highlighted here.
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 4 December includes: 1) Global Forum Holds 16th Plenary Meeting in Lisbon; 2) EU Parliament ECON Report on DEBRA; 3) OECD Publishes Effective Carbon Rates Report 2023; 4) Global Forum’s 2023 Update on Automatic Exchange of Financial Account Information; and 5) OECD to Publish 2023 Revenue Statistics Report. Visit their latest news page here.
- Global Tax News Top 10 - November 2023
The November 2023 issue includes: 1) UN Approves Africa Initiative for United Nations Tax Leadership; 2) OECD Statement on International Tax Reform Developments; 3) EU Reaffirms Commitment to Pillar 2; 4) European Commission’s Assessment in Apple Case Upheld in Opinion of ECJ’s Advocate General; 5) OECD: MNEs Continue Reporting Low-Taxed Profits Even in High-Tax Jurisdictions; 6) European Parliament ECON Report on BEFIT; 7) 48 Countries to Implement OECD Tax Transparency Standards for Crypto-Assets by 2027; 8) European Commission Adopts 2024 Work Programme; 9) EU Tax Observatory Calls for Global Minimum Wealth Tax; and 10) Meeting of the EU Parliament Permanent Taxation Subcommittee.
Pillars One and Two
- Pillar Two: Policy, politics and interaction with Pillar One
In this Cross-border Tax Talks episode from 7 December, Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Tax Symposium in Rome, where he’s joined by Will Morris. Doug and Will discuss generally how the Pillar Two process has been going. They wonder how tax authorities and courts will administer and adjudicate in their jurisdictions, and what will become of the potential FAQs and future administrative guidance from the OECD. They then discuss the recent EC guidance, and whether countries will be able to bring in the OECD guidance retroactively. Finally, Doug and Will touch on how business have participated thus far in the process.
- How to get Pillar 2 ready: a step-by-step approach
In this Tax Bites podcast episode the speakers elaborate on PwC’s recently published Pillar Two Guide for EMEA Multinational Enterprises, which sets out the steps you need to take to be Pillar 2 compliant.
- Pillar One: Policy, politics and interaction with Pillar Two
In this Cross-border Tax Talks episode from 30 November, Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what’s next. Finally, they address what might happen with digital services taxes and what companies should do next.
Latest updates, 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 including:
- Indonesia confirms the completion of its internal procedures for the entry into effect of the provisions of the Multilateral BEPS Convention under Article 35(7)(b) and extends its application on existing treaties
- Entry into force of agreements notified pursuant to Article 2 of the Convention
Dividend Tax Fraud
This OECD report provides a number of recommendations for countries around recognising the risk, improving domestic co-ordination and expanding international co-operation to address the illicit tax practice of dividend stripping.
Enhancing global collaboration is key in tackling tax crime in the digitalising economy
Over 120 experts on tax crimes and other financial crimes, including the heads of financial crime agencies and other senior law enforcement authorities from 46 jurisdictions, met on 5-7 December for the Sixth OECD Forum on Tax and Crime (FTC) in Rome, Italy. Against the background of the new challenges and opportunities brought about by the rapid digitalisation of the economy, delegates discussed how countries can further enhance international co-operation in order to maximise the disruption of tax crimes and related illicit financial flows. Read more in this OECD item.
Global Forum on Transparency and Exchange of Information for Tax Purposes
Over 420 delegates from 115 jurisdictions and 13 international organisations recently convened in Portugal, on the occasion of the 16th Global Forum plenary meeting to discuss the results of almost 15 years of international tax co-operation to address tax evasion, and to define the way forward to ensure the effective implementation of the international tax transparency standards. Read more in this OECD item.
International Tax News - November 2023
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments. Among the topics featured in this month's edition are: 1) Hong Kong gazettes of the bill on further refinements to FSIE regime in Hong Kong; 2) Canada Revenue Agency officially designates first notifiable transactions; 3) Hungary, Liechtenstein, and Cyprus move ahead with Pillar Two; and 4) The UAE publishes additional guidance on the corporate tax regime.
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. In this edition, from 28 November, we cover:
- the EU Parliament's ECON committee recommendations including deferral of the VAT in the Digital Age package;
- the Netherlands has postponed the penalty regime for its VAT e-commerce One Stop Shop;
- Norway has expanded the requirements for its VAT e-commerce regime;
- Brazil has progressed the gradual overhaul of its indirect tax system with the introduction of a two tier VAT regime;
- a statement by 48 countries of their intention to implement the OECD's crypto asset reporting framework (CARF);
- Italy's issuance of a Circular on taxation of crypto assets, including digital currency;
- the UK has incorporated its guidance on digital platform operator reporting into the HMRC manual on information exchange; and
- Canada has confirmed in its fall economic statement the intention to go ahead with introducing a digital services tax.
Environmental, Social and Governance (ESG)
- Live from COP28
Listen back to our LinkedIn Live, recorded on 5 December, for on the ground insights from COP28. Our Head of Platforms Carl Sizer, was joined by our Sustainability Practice Leader, Lynne Baber, and Amal Larhlid, an ESG Partner in PwC Middle East, and shared insights on key areas of progress, the evolving role of business, and what they hope to come out of COP28. Watch here.
- How can CFOs drive the mindset shift that is needed to transition to net zero?
In our latest report with ACCA and IFAC we explore how CFOs and finance teams are adapting their role, using their professional skills, and acquiring new areas of knowledge and capability needed to transition to a lower-emission society. Read more.
Decisive action needed to harness digital trade and investment for inclusive sustainable development, finds new UN report
Digital trade and investment are driving forces of the modern economy, and growth in the Asia-Pacific region has exceeded the global average, with the region now accounting for a quarter of the US$ 4 trillion trade in digitally deliverable products. However, digital trade and investment remain highly uneven, according to the new Asia-Pacific Trade and Investment Report 2023/2024: Unleashing Digital Trade and Investment for Sustainable Development, produced by the United Nations Economic and Social Commission for Asia and the Pacific (ESCAP), the United Nations Conference on Trade and Development (UNCTAD) and United Nations Industrial Development Organization (UNIDO). While six economies in the Asia-Pacific region are responsible for 85% of the region’s digitally deliverable exports, least developed countries (LDCs) account for less than 1%. Read more in this press release.
Final amendments to new thin capitalisation regime
On 28 November 2023, amendments to Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Bill 2023 - which contains the proposed reforms to Australia’s thin capitalisation regime - were released in advance of their introduction in the Senate. This is likely to be the final round of changes before the Bill completes its passage through Parliament. As such, the Bill, combined with these amendments, offers the complete picture of how the new thin capitalisation regime will operate.
See here for latest updates.
How to get Pillar 2 ready: a step-by-step approach
In this Tax Bites podcast episode the speakers elaborate on PwC’s recently published Pillar Two Guide for EMEA Multinational Enterprises, which sets out the steps you need to take to be Pillar 2 compliant.
Expected change in Belgian CFC regime
The CFC regime Belgium, introduced back in 2017, taxed non-distributed income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage (option B). Basically, this option required that the significant people functions generating the CFC income were located in Belgium. The draft law foresees a change as the focus now is on the taxation of passive income – namely interest, royalties, dividend, income from disposal of shares, but amongst others also rental income and income from invoicing companies that earn sales and services income from goods and services with adding no or little economic value – subject to low taxation abroad (defined as half of the taxation that would occur under the Belgian rules), unless the taxpayer can prove that sufficient substance is available locally. Read more in this PwC news item.
Bill C-59 introduces EIFEL, environmental incentives, digital services tax, GAAR changes and more
On 30 November 2023, the federal government tabled Bill C-59, which includes legislation to implement a variety of tax measures, many of which have been long awaited by taxpayers and tax practitioners. Key tax measures include: 1) implementation of the excessive interest and financing expenses limitation (EIFEL) regime; 2) provision for the refundable investment tax credits (ITCs) for clean technology equipment and for carbon capture, utilisation and storage (CCUS); 3) implementation of the Digital Services Tax Act; and 4) strengthening of the general anti-avoidance rule (GAAR). This PwC Tax Insights highlights the income tax-related and other measures included in Bill C-59.
Tax group and corporate reconstructions
In the case of a merger of a corporation into a partnership during the year, the Supreme Tax Court decided that the acquiring legal entity (as the "new" controlling company) also fulfils the requirement of financial integration as a prerequisite for a tax group (”Organschaft”) of the former controlling company, even if the conversion is not made with retroactive effect from the beginning of the financial year. Read more in this PwC blog.
Excessive payments not tax-free as tips
In two decisions, the Tax Court of Cologne decided that payments of EUR 50,000 and some EUR 1.3 million respectively made to authorised representatives of a GmbH do not generally qualify as tax-free tips but are rather part of the employment and subject to the personal income tax of the recipients. Read more in this PwC blog.
Bill on tax deduction for spectrum utilisation fees gazetted
Following an announcement by the Financial Secretary in Hong Kong’s 2023/23 Budget in February 2023, the Inland Revenue (Amendment) (Tax Deductions for Spectrum Utilization Fees) Bill 2023 was gazetted on 1 December 2023. The Bill provides for tax deductions for spectrum utilisation fees (SUF) to be paid by future assignees of radio spectrum. The proposed deduction will resolve (on a prospective basis) this long-standing industry-wide issue and encourage mobile network operators (MNOs) to enhance their telecommunications services. However, the deductibility of SUF derived in all past auctions will remain in dispute and we urge the Government to consider providing tax deductions for other ‘black hole’ expenditures, so long as they are incurred in producing profits chargeable to tax in Hong Kong. Read more in this PwC Newsflash.
Tribunal rules on definition of PE and fees for technical services (FTS)
The Delhi bench of the Income-tax Appellate Tribunal has allowed an appeal in favour of the nonresident taxpayer, concluding that profits earned by the taxpayer by offshore sale of goods and other tangible assets should not be attributable to its Indian subsidiary. The Tribunal, while deciding on the facts of the case, observed inter alia that the non-resident taxpayer had exported goods to Indian customers on a principal-to-principal basis, effected through both delivery and receipt of payments for such sales outside India. The Tribunal was of the view that it is not sustainable to hold that the taxpayer has a permanent establishment (PE) merely based on the existence of an Indian subsidiary, without any supporting evidence to prove the existence of such PE. Based on the facts of the present case, the Tribunal concluded that the non-resident taxpayer did not have a PE in India; accordingly, profit attribution to the taxpayer on this account is liable to be deleted. The Tribunal further confirmed, based on the facts involved, that mere reimbursement of expenses, being lab-testing charges, cannot be considered as fees for technical services (FTS) in the hands of the taxpayer receiving such reimbursement from its Indian subsidiary. Read more in this PwC Tax Insights.
Tribunal denies taxability of offshore supplies and services inextricably linked with offshore supplies
In a recent ruling, the Delhi bench of the Income-tax Appellate Tribunal was of the view that no part of the consideration received outside India by a non-resident entity for offshore supplies of plant and equipment can be deemed to accrue or arise in India as per section 9 of the Income tax Act, 1961. Moreover, such consideration would only be in the nature of business profits not attributable to a permanent establishment (PE) in India; hence, it is not taxable as per the provisions of the India-Germany double tax treaty (treaty). In addition, receipts from offshore services that primarily involve offshore supply of drawings and designs, which are inextricably linked with the offshore supply of plant and equipment, do not give rise to any income accruing or arising in India; therefore, they are not taxable under the Act. Moreover, as the designs and drawings were prepared outside India, the question of bringing to tax any part of the consideration in accordance with Article 7 of the treaty cannot be sustained. Read more in this PwC Tax Insights.
Receipts from offshore supply of goods or equipment not taxable in India
In a recent case, the Delhi bench of the Income-tax Appellate Tribunal was of the view that receipts from offshore supply of goods and equipment are not taxable in India. The Tribunal observed that the supply of goods took place outside India, title over the goods was transferred outside India and payment was received outside India. The Tribunal also noted that the mere existence of an Indian subsidiary would not lead to the creation of a permanent establishment (PE). This is because no material on record substantiates that the Indian subsidiary was involved in any manner in the work of design, manufacture, testing or supply of goods from China on a cost, insurance, and freight (CIF) basis. The Tribunal also observed that a cross-fall breach clause in the onshore and offshore contracts cannot lead to these two different and distinct contracts as being composite in nature. Read more in this PwC Tax Insights.
Pillar Two: Preparing for change
Ireland’s Pillar Two rules will take effect for large businesses with accounting periods beginning on or after 31 December 2023. As the effective date looms ever closer, there are certain actions you should take to ensure your business is Pillar Two-ready. Read more in this PwC article.
Barriers to Business report published
Commissioned by the Minister for Sustainable Economic Development, the Barriers to Business report identifies eight areas that are creating barriers to doing business in Jersey, and gives 38 recommendations to address them. Read more in this press release.
Inland Revenue issues guidance on new corporate tax incentives
The Inland Revenue Board of Malaysia has recently released two guidance documents clarifying a tax incentive for companies engaged in food production and on the investment tax allowance for certain ventures.
Tax Agency confirms additional tax reliefs
Malta's Tax and Customs Administration has confirmed a number of measures intended to support smaller businesses. The measures, which were included in the territory's earlier Budget, include the removal of the requirement on small businesses to engage an auditor and draw up an auditor's report. The Seed Investment Scheme will be extended, which offers incentives (in the form of tax credits) to Maltese companies which have invested in startups and which satisfy the relevant due diligence procedures.
- Corporate Tax - Guide on Taxation of Foreign Source Income released
The Federal Tax Authority (FTA) has released a Corporate Tax (CT) Guide on Taxation of Foreign Source Income (FSI). The document includes detailed guidance on who is taxable, which foreign income is taxable, how to calculate the taxable income, how to apply any available exemptions/reliefs, how to apply tax credit etc. Read more in this PwC news item.
- Guide on Accounting Standards released
The Federal Tax Authority (FTA) has released a Corporate Tax (CT) Guide on Accounting Standards and their interaction with Corporate Tax. The document includes detailed guidance on accepted accounting standards, taxation under realisation basis of accounting, adjustments to accounting income and transitional rules. Read more in this PwC news item.
- UAE begins to legislate for Pillar Two minimum tax
The United Arab Emirates has published new Federal Decree Law No. 60 of 2023, which amends the corporate tax law to add provisions for the implementation of the Pillar Two minimum tax on large multinational enterprises (MNEs).
Minimum profit tax 2024 in next phase: update
The Dutch Draft Bill Minimum Taxation Act 2024, also known as Pillar Two, was adopted by the House of Representatives on 26 October. This PwC article addresses the bill including Memorandum in response to the Report of the House of Representatives dated 11 September, the Memorandum of Amendment dated 13 October 2023 and the Memorandum in response to the second report by the Senate dated 1 December 2024. It also addresses the second Memorandum of Amendment of the 2024 Tax Plan. The memoranda address several interesting aspects, including the interaction between Pillar Two and corporate tax, the incorporation of the OECD administrative guidance and multilateral dispute resolution.
Tax Policy Bulletin - December 2023
Tax Policy Bulletin is a regular round-up of recent tax headline news. In this edition we cover: 1) Incoming coalition Government’s tax policy; 2) Tax treaties; 3) Digital Services Tax; and 4) Round-up of open consultations and other recent developments.
For the latest updates on current topics, see this PwC Switzerland Insights page.
Taiwan Tax Update November 2023
This edition includes: 1) Extension of deadline to 10 years by Ministry of Finance for foreign profit-seeking enterprises applying for recalculation of reduced withholding tax.
Proposed regulations on partnership related-party transactions reflect statutory changes
Treasury and the IRS recently released proposed regulations that address the disallowance or deferral of deductions under Sections 267 and 707 for losses and expenses in certain transactions with partnerships and related persons. The proposed rules would update the current regulations, promulgated in 1958, to reflect statutory changes since 1982 and indicated Congressional intent to treat partnerships as an entity rather than as an aggregate of its partners for purposes of applying related-party loss disallowance rules. Read more in this PwC Tax Insights.
Tax Court limits meaning of “limited partner” for self-employment tax purposes
In Soroban Capital Partners v. Commissioner (161 T.C. No. 12), the Tax Court recently held that determining whether a limited partner in a state law limited partnership is a limited partner for purposes of the Section 1402(a)(13) exclusion from self-employment tax for limited partners requires an inquiry into the function and roles of the limited partner. Under the decision, a limited partner who actively participates in the business of the partnership would not be able to exclude his distributive share of income or loss from net earnings from self-employment. Read more in this PwC Tax Insights.
Policy on Demand series
- Camp on a 2024 tax package and more
The much hoped-for year-end tax package will likely make an appearance at the start of the new year, according to a conversation with House Ways and Means Committee Chairman Jason Smith. In this episode from 8 December, Chairman Dave Camp talks about that and other issues, including Pillar Two, during their Q&A at PwC’s 2023 Global Tax Symposium.
- Is it now or 2024 for TCJA extenders and Taiwan bill?
With only two weeks remaining before its scheduled adjournment, what will it take to enact a year-end tax package and pass the Taiwan tax bill? In this episode from 4 December, Rohit Kumar talks about what could get these efforts over the finish line – and what it might look like if they don’t.
- Tax is embracing the moment as a strategic value driver
In this episode from 29 November, Ken Kuykendall discusses how tax executives can play a more strategic role in the business, address talent challenges, leverage technology for efficiency gains, and align tax functions with organisation-wide priorities.
- Week in Review
- 8 December - Pam Olson talks about her key takeaways from this week, which include oral arguments before the Supreme Court in Moore v US and continued watching and waiting for Congress to act on extenders. She also answers the question she received most this week (also about the Moore case) and where companies should focus their attention in the coming week. Watch here.
- 1 December - House Republicans are pushing their leadership to extend TCJA provisions before year-end. The Taiwan double taxation bill could provide the vehicle. Now is the time to press Congressional leaders to make these provisions a priority. Watch here.
Tax Readiness webcast series
- Tax Readiness: Future of Tax - Topics shaping the tax agenda
The opportunity for Tax to enable and influence business strategy has never been greater – from business model reinvention, to climate investments, and Pillar Two. On this webcast taking place on Tuesday 12 December at 7pm, we'll share the new capabilities that leading tax functions are prioritising to support their organisation's broader commercial strategy. Register here.
- Tax Readiness: New foreign currency branch rules bring big changes
The proposed foreign currency regulations include significant changes, including the determination of taxable income or loss and foreign currency gain or loss with respect to a qualified business unit, along with elections and a new transition rule. In this webcast replay from 29 November our panel of specialists discuss these changes and more.
- Tax Readiness: Don't leave value on the table - elevating your compliance function
As new technologies emerge and reporting expands globally, businesses need to continue to update and develop their technology systems to keep pace with the ever-increasing demands. A connected data strategy is the foundation for a streamlined compliance process and opens the door to opportunities in transformation, ERP integration and increased global coordination. Watch this webcast replay from 7 November, where our panel of specialists discuss how businesses can embrace an updated data strategy to help manage reporting and compliance while building value outside of the tax department.
State and Local tax
- Delaware verified report notices require prompt action from unclaimed property holders
Delaware is sending notices to request that unclaimed property holders provide evidence within 30 days to support that they filed a 2022 unclaimed property report. Read more in this PwC Tax Insights.
- Maine Supreme Court sources revenue from claims adjudication services to pharmacy locations
The Maine Supreme Judicial Court has ruled that revenue from claims adjudication services was received at the location of retail pharmacies and was not sourced to client locations. Read more in this PwC Tax Insights.
You can sign up for Tax Alerts issued by the US to be emailed to you. Subscribe using the link on this page. A back catalogue of previous webcasts and other resources are available on our US tax reform hub here.