International Tax
1 week ago
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This edition includes: 1) Details of draft legislation published on HMRC "Legislation Day"; 2) 130 countries and jurisdictions have joined a new two-pillar plan to reform international taxation rules; and 3) An overview of the UK patent box regime.
International Tax
1 week ago
The Spanish National High Court has rejected the obligation of the taxpayer to prove the existence of valid economic motives when the Spanish Tax Agency has not carried out a minimum evidential investigation to justify the application of the anti-abuse provision.
International Tax
1 week ago
A new compliance requirement is now imposed on companies doing business in Turkey, calling for declaration of the ultimate beneficial ownership (UBO) information to the tax office.
International Tax
1 week ago
The Australian Treasury has released an exposure draft law for comment that seeks to give effect to the Federal Government’s announcement in its 2019-20 Mid-Year Economic and Fiscal Outlook that it would introduce a third-party reporting regime for the sharing economy. A Fact Sheet was also released and summarises the key aspects of the proposal.
International Tax
1 week ago
The Chief Minister delivered his Budget address in Parliament on 20 July 2021.
International Tax
1 week ago
Taxpayers considering major projects in Texas should act soon in seeking time to secure the substantial benefits afforded by the Chapter 313 program.
Transfer Pricing
1 week ago
The IRS on July 16 released AM 2021-004, a legal advice memorandum issued by Associate Chief Counsel (International) (the "CCM"). The CCM provides non-taxpayer-specific legal advice regarding the potential timing and amount of adjustments arising from transfer pricing examinations of stock-based compensation (SBC) costs involving taxpayers' cost-sharing agreements (CSAs) that included so-called "reverse claw-back" provisions which are assumed to have been triggered by a final decision in the Altera litigation.
International Tax
1 week ago
Foreign companies investing and operating in the United States will want to carefully review the Green Book, which contains important new details regarding tax proposals that would make sweeping changes to the US international tax rules enacted as part of the 2017 tax reform law (Tax Cuts and Jobs Act, or TCJA). This Insight looks at the key international tax proposals affecting inbound companies.
Tax & The Digital Economy
3 days ago
The latest addition to our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of the digitalisation of business.
International Tax
1 week ago
The latest edition of our Korean tax update.
International Tax
1 week ago
A long-standing tax dispute has existed in Michigan regarding what constitutes a taxable ‘use’ of direct mail shipped from outside the state. The state has often asserted that the act of directing mailings into the state or the ability to recall an item from the US Postal Service (USPS) would constitute sufficient ‘control’ over the mailings to create a use tax consequence. The Michigan Court of Appeals recently affirmed that a corporation did not have ‘sufficient retention of control’ of advertising materials printed out-of-state and delivered by a third party vendor to Michigan customers to constitute ‘use’ of such materials in-state.
International Tax
1 week ago
California is one step closer to joining the growing number of states adopting pass-through entity (PTE) tax legislation in response to the 2017 federal tax reform legislation. For federal income tax purposes, the 2017 tax reform limited individuals’ itemized deduction to $10,000 for their separately stated state and local income, sales, and property taxes (SALT).
International Tax
2 weeks ago
Enacted on June 30, H.B. 110, the fiscal year 2022-23 budget bill, includes several tax credit and incentive changes that create new programs and enhance existing programs.
International Tax
2 weeks ago
The European Commission has published a number of green taxation measures as part of a package called the "Fit for 55 package".
International Tax
2 weeks ago
Enacted on June 30, H.B. 110, the state’s budget bill, makes several tax changes, including:
International Tax
1 week ago
The historic negotiations taking place this year at the OECD, G-7 and G-20 will be critical to the future of international tax reform. In this webcast, held on Tuesday 20 July 2021, we provided an update on the recent OECD and G-20 negotiations to help those in Tax, Treasury, Operations and the C-Suite navigate this complicated landscape.
International Tax
3 weeks ago
At the 9th - 10th July G20 meeting, the G20 endorsed the position reached by 132 of the 139 Inclusive Framework members to move forward with the two-Pillar approach and to begin work on the technical discussions in advance of the next OECD/IF and G20 meetings in October.
International Tax
3 weeks ago
The Brazilian Supreme Federal Court recently concluded the judgment of the final motion on its 2017 precedent-setting decision, holding that the Brazilian State-level VAT (‘ICMS’ in Portuguese) should not be included in the tax base of the Federal Social Contributions on Gross Revenues (‘PIS and COFINS’).
International Tax
3 weeks ago
The Brazilian Federal Government recently announced the second phase of its proposed comprehensive tax reform, focusing on income tax. This proposal is in addition to the more than 20 tax bills that were already being intensively debated in the National Congress, particularly in the Senate. The government’s current proposal for corporate tax reform and/or reintroduction of a dividend withholding tax would significantly increase the Brazilian tax burden on many businesses, particularly on foreign investors.
International Tax
3 weeks ago
Welcome to the July edition of Australia's Monthly Tax Update, keeping you up to date on the latest Australian and international tax developments.
Tax & The Digital Economy
July 5th 2021 10:22 AM
On July 1, 130 countries of the 139 members of the OECD Inclusive Framework on Base Erosion and Profit Shifting committed to fundamental changes to the international corporate tax system. The 130 countries include the G7 members (Canada, France, Germany, Italy, Japan, the United Kingdom and the United States), emerging economies like Brazil, China and India, and jurisdictions like Switzerland, Singapore, Bermuda, and the Cayman Islands. However, Ireland, Hungary, Estonia, Barbados, Kenya, Nigeria, Peru, Sri Lanka, Saint Vincent and the Grenadines did not sign on to the consensus.
Tax & The Digital Economy
July 5th 2021 08:49 AM
On 22 June 2021 the OECD issued a report entitled “Model Reporting Rules for Digital Platforms: International Exchange Framework and Optional Module for Sale of Goods.” The Report introduces an optional module to the model reporting rules for digital platform operators published by the OECD in July 2020, extending the scope of the model reporting rules to the sale of goods and the rental of transportation means. Furthermore, the Report provides for an international legal framework to exchange information on income derived through digital platforms.
International Tax
July 2nd 2021 12:12 PM
President Biden has proposed extensive infrastructure and other spending initiatives, including tax incentives for clean energy and domestic manufacturing, as well as corporate and individual tax increase proposals designed to offset the costs of his spending proposals.
International Tax
June 30th 2021 09:09 AM
On May 28, the Department of the Treasury released the General Explanation of the Administration's Fiscal Year 2022 Revenue Proposals (“Green Book”), outlining a number of proposed amendments to the Internal Revenue Code (“IRC”), including significant changes for corporate taxpayers. Among other considerations, these proposals represent changes to existing corporate tax regimes, and have important implications from both an income and non-income tax accounting perspective.
International Tax
June 29th 2021 10:44 AM
Our latest update includes: 1) a recording of our PwC panel’s recent discussion of how the G7 Finance Ministers’ agreement might affect your business; and 2) an invitation to a webcast where we will explore the tax and legal considerations of hybrid working.
The ITT update will be taking its summer vacation early this year, so our next edition will be published on 26 July.
International Tax
June 28th 2021 07:36 AM
Argentine Law 27,630, which introduced amendments to the corporate income tax (CIT) law, entered into force on June 16, 2021. Taxpayers conducting business in Argentina should model how the amended CIT and withholding rates could impact current tax costs and operations and any planned transactions.
International Tax
June 28th 2021 03:28 PM
The Australian Taxation Office has released a draft taxation ruling which sets out the Commissioner of Taxation’s preliminary views on the income tax treatment of receipts from the distribution and licensing of software, as distinct from “simple use” by end-users of the software. The draft ruling has a particular focus on the circumstances where receipts will be treated as royalties under arrangements involving the distribution of packaged software, digital software distribution and cloud computing arrangements including software-as-a-service (SaaS). This has the potential to be quite broad such that any business where software is fundamental to the delivery of services should also consider the draft ruling.
Real Estate
June 24th 2021 03:22 PM
The current double tax treaty (DTT) between France and Belgium dates from 1964 and has been updated throughout the years via various protocols and most recently the Multilateral Instrument (MLI). The Belgian and French government decided a couple of years ago to conclude a new DTT with the objective to achieve a BEPS compliant text. A draft version of this new DTT that would be submitted to the Flemish government for approval was briefly published on the website of the Flemish government and gave some more insights on the expected content. The entry into force is not yet known.
International Tax
June 24th 2021 08:35 AM
Register to watch this recent webcast replay for a deeper discussion and understanding of how the G7 Finance Ministers’ agreement might affect your business.
Transfer Pricing
June 23rd 2021 11:56 AM
Committees of the European Parliament and the Council of the EU have agreed to compromise text on a Directive on public country-by-country reporting (‘Public CbCR’). The text will amend Directive 2013/34/EU, which deals with financial reporting of certain types of undertakings (the Accounting Directive).
International Tax
June 23rd 2021 08:29 AM
The latest edition of our Korean tax update.
International Tax
June 22nd 2021 03:23 PM
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's tax treatments for corporate amalgamations; 2) Uruguay Corporate deductions – Micro and small enterprises; 3) US Treasury ‘Green Book’ describes Biden’s tax proposals for businesses; and 4) G7 Finance Ministers commit to Pillars One & Two, including global minimum tax rate of ‘at least’ 15%.
International Tax
June 14th 2021 02:46 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Topics covered in this edition include: G7's historic commitment to global tax reform and President Biden's tax proposals for business.
International Tax
June 14th 2021 10:22 AM
The Australian Taxation Office has amended its guidance on the rules regarding the creation of a permanent establishment in Australia in response to the COVID-19 pandemic.
International Tax
June 11th 2021 07:59 AM
This publication provides updates on recent tax and trade issues and developments of interest to global companies operating in the United States.
International Tax
June 11th 2021 12:12 PM
EU tax news is a bimonthly newsletter with summaries of all the relevant ECJ and national court cases and decisions, and EU policy initiatives related to EU direct tax law and state aid. The newsletter is prepared by members of PwC's EU direct tax group (EUDTG) from across Europe.
International Tax
June 9th 2021 08:17 AM
The G7 Finance Ministers announced an agreement on June 5, in which the participating countries committed to new taxing rights that allow countries to reallocate some portion of profits of large multinational companies to markets (i.e., where sales arise—'Pillar One’), as well as enact a global minimum tax rate of at least 15% (‘Pillar Two’). The meeting marked an early test of whether the US position on the OECD Inclusive Framework’s ‘Taxation of the Digitalising Economy’ project would provide momentum to finding a common base for agreement.
Legal
June 8th 2021 11:07 AM
In this article, first published in Tax Journal, PwC's Peter Halford and Mark Whitehouse focus on the likely impact of Brexit on direct tax cases.
International Tax
June 8th 2021 11:34 AM
Welcome to the June edition of Australia's Monthly Tax Update, keeping you up to date on the latest Australian and international tax developments.
International Tax
June 7th 2021 12:19 PM
The US Treasury on May 28 released the much-anticipated 'General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals' ('Green Book'). The Green Book serves as a guidepost for the Administration’s proposed tax legislation, describing current law, proposed law, the Administration’s policy rationale for the proposals, and revenue projections. While the Green Book reflects the Biden Administration’s recommendations, Congress will be responsible for drafting and enacting any tax legislation.
International Tax
June 8th 2021 07:46 AM
The European Commission recently proposed a new regulation to address foreign subsidies, which in certain cases are seen to be distorting the internal market.
International Tax
June 9th 2021 10:35 AM
Watch the replay from this webcast held on Tuesday 8 June 2021 which focused on key state legislation impacting corporate, passthrough entity, individual, and indirect taxes.
International Tax
June 4th 2021 11:05 AM
On 1 June 2021, negotiators for the European Parliament and the Portuguese EU Council Presidency, on behalf of the Council of the EU (EU-27 Member States), provisionally reached a compromise deal on the EU’s draft Directive on public country-by-country reporting (‘Public CbCR’) for big multinational groups, according to a Council of the EU’s press release.
International Tax
June 1st 2021 08:23 PM
The First-tier Tax Tribunal (FTT) in Aozora GMAC Investments (Aozora) v HMRC has allowed the taxpayer’s appeal, ruling that the Limitation of Benefits clause in the US-UK double tax treaty is not an ‘express provision’ that relief by way of credit is not to be given under the treaty and therefore that it does not prohibit Aozora from claiming unilateral credit relief in the UK. Taxpayers considering whether they are entitled to credit relief in the UK for tax that is not relieved by an applicable double tax treaty should consider the potential implications of this ruling for their own arrangements and seek advice where necessary.
Tax & The Digital Economy
June 2nd 2021 12:39 PM
This edition includes announcements on India's SEP thresholds, Australia's proposed sharing economy reporting regime and revised USTR hearings on DSTs. The progress of US domestic proposals may impact on Pillar One and Two discussions and ATAF has put forward its revised proposals. The EC has released a Communication including its intentions on digital measures. Kenya's 2021 Finance Bill has proposed some changes to the definition of a PE, the DST and VAT rules while the IMF has released a paper on the challenges faced by countries in setting VAT rules.
International Tax
June 1st 2021 08:58 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Highlights in this edition are: 1) FTT concludes LoB clause is not an ‘express provision’ denying credit relief; 2) EU General Court delivers two State aid judgments in Amazon and Engie; 3) The rise of hybrid working: How to transform your organisation for our changed world; 4) The post-pandemic world of work: can you let employees work from anywhere? and 5) Our April edition of International Tax News.
International Tax
June 1st 2021 07:48 AM
The US Treasury has released a 114-page “Green Book” general explanation of tax proposals included in President Joe Biden’s fiscal year (FY) 2022 budget submission to Congress, also released the same day. The Green Book provides new details on proposals to increase corporate and individual taxes to help offset the $4.1 trillion combined cost of President Biden’s previously proposed American Jobs Plan and American Families Plan.
International Tax
June 4th 2021 08:16 AM
Watch the replay of this webcast held on Thursday 3 June 2021 where our panel walked through Treasury's 'Green Book,' which adds details to President Biden's FY22 Budget proposals, and informs Congress.
International Tax
May 28th 2021 03:53 PM
At a public forum in April 2021, a Treasury official stated the United States desires to amend existing income tax treaties with Switzerland and Israel, and that the United States has opened tax treaty negotiations with Colombia, has completed tax treaty negotiations with Norway and Romania, and is engaged in ongoing tax treaty discussions with Croatia.
This treaty activity contrasts with recent US tax treaty history, where, in 2019, following a lengthy hiatus in the tax treaty approval process, four US tax treaty protocols, which had been negotiated and signed years before, entered into force.
International Tax
May 27th 2021 09:15 AM
Among the topics featured in this month's edition are: 1) Canada’s 2021 budget addresses mandatory disclosure, DST, interest limitation, and hybrid mismatches; 2) Australian Tax Office proposes hybrid rules guidance; 3) France updates list of non-cooperative states and territories; and 4) New CIT preferential policies for small and thin-profit enterprises (STEs) and super R&D deduction.
International Tax
May 27th 2021 05:20 PM
The 2021-22 Victorian State Budget was delivered on 20 May 2021 by Treasurer Tim Pallas. The key feature of the 2021-22 Budget was the recovery from the economic impact of COVID-19. However, the resulting cost is manifested in another key feature of the Budget, tax increases and new taxes and levies.
International Tax
May 27th 2021 02:42 PM
The latest edition of our Korean tax update.
International Tax
May 27th 2021 07:03 AM
In this webcast held on Wednesday 26 May 2021, PwC professionals from our Tax and Deals practices had a timely discussion of the many factors impacting the current deals environment including the prevalence of ESG, the use of SPACs, and anticipated tax changes.
International Tax
May 25th 2021 07:58 AM
The European Commission released a “Communication on Business Taxation for the 21st Century” on 18 May 2021, setting a tax agenda for the next two years with five key actions. The aim is to align the EU tax framework with the new realities of the globalised and digitalised economy post-Covid, and to ensure that Member States’ tax systems are fit for purpose.
International Tax
May 24th 2021 10:28 AM
The US Treasury Department has published an interim final rule on a law prohibiting states from using certain federal aid to offset tax reductions.
International Tax
May 21st 2021 11:41 AM
The Australian Taxation Office has released a draft Practical Compliance Guideline on cross-border arrangements connected with intangibles. The draft PCG covers a broad range of issues including intangible transfers, the development, enhancement, maintenance, protection and exploitation (DEMPE) functions, and the characterisation of intangible payments.
Indirect Tax
May 21st 2021 12:56 PM
On 18 May 2021, the European Commission published a Communication on EU Business Taxation for the 21st Century in which it sets out its vision and measures for both the short and longer term.
Transfer Pricing
May 20th 2021 09:58 AM
Irish Revenue recently released Part 35A-01-01, Transfer Pricing Tax and Duty Manual (Tax and Duty Manual). The Manual seeks to give taxpayers additional guidance on the new rules introduced by Finance Bill 2019.
International Tax
May 21st 2021 07:54 AM
The temporary loss carry-back rules were a welcome announcement by the Government in the Federal Budget handed down on 6 October 2020. These rules are designed to provide temporary cashflow support to companies that were previously in a tax paying position but who now find themselves in a tax loss position due to the COVID-19 pandemic and/or through obtaining faster deductions for depreciation under the new instant asset write-off measures. The regime, as originally announced, was to be in place for three years. In the 2021-22 Federal Budget, the Government announced it would be extended for an additional year.
International Tax
May 18th 2021 11:37 AM
The General Court of the European Union on 12 May 2021 confirmed the European Commission's final decision in the GDF Suez (now Engie) State aid cases. Read more in this PwC EU Direct Tax Group newsalert.
International Tax
May 18th 2021 11:33 AM
In its decision of 12 May 2021, the General Court of the European Union annulled the European Commission's final decision in the Amazon State aid case. Read more in our PwC EU Direct Tax Group newsalert.
International Tax
May 17th 2021 05:35 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
Global Mobility
May 17th 2021 02:03 PM
Treasurer Josh Frydenberg handed down the 2021-22 Australian Federal Budget on Tuesday 11 May 2021. A key focus of this year’s Budget is to attract and retain the ‘best and brightest’ talent in Australia, encourage workforce participation, reduce compliance costs, build confidence and certainty in the tax system. It is no surprise that tax measures play a key role in delivering this agenda. A number of measures announced are relevant to global employers and their mobile employees.
International Tax
May 28th 2021 11:55 AM
Join us for a webcast on Thursday 27 May 2021 at 7pm where we will discuss the legislation recently published in Mexico that will significantly impact multinational entities with operations or investments in Mexico.
International Tax
May 10th 2021 02:26 PM
The Cyprus Parliament on March 18 approved the draft Bill amending the Law on Administrative Cooperation in the Field of Taxation, implementing DAC6. In addition, the Cypriot Ministry of Finance submitted two bills to Parliament to amend tax legislation to strengthen Cyprus’ tax framework for preventing tax abuse, tax evasion, and tax avoidance. The new tax treaty between Cyprus and Egypt, which was signed on October 8, 2019, and which entered into force on July 31, 2020, is effective as of January 1, 2021.
International Tax
May 10th 2021 04:02 PM
Pursuant to a legislative override of the governor’s veto, S.B. 50 which was recently enacted, provides the following changes applicable for tax years beginning after December 31, 2020: 1) 100% subtraction modification for GILTI and 163(j) disallowed interest; 2) Decoupling from IRC Section 118 capital contribution changes enacted by the 2017 tax reform act (the 2017 Act); and 3) Modifying business meal expense deductions. Additionally, for net operating losses incurred in tax years beginning after December 31, 2017, Kansas replaces its 10-year NOL carryforward with an unlimited carryforward. Finally, Kansas extends the filing deadline for 2020 corporate income tax returns to be one month following the federal deadline.
International Tax
May 5th 2021 04:58 PM
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments.
International Tax
May 7th 2021 03:54 PM
Florida has enacted legislation requiring remote sellers and marketplace providers to collect and remit sales and use taxes, effective July 1, 2021.
International Tax
May 4th 2021 06:39 PM
Senate Bill 65, enacted on 15 April 2021, eliminates certain requirements from the High Performance Incentive Program (HPIP). Effective upon enactment, taxpayers no longer have to qualify for the Kansas Industrial Training (KIT) or Kansas Industrial Retraining (KIR) workforce training tax credits, or make required investments in employee training, to qualify for the HPIP. For projects placed in service on and after 1 January, 2021, a taxpayer may transfer up to 50% of HPIP tax credits to another taxpayer.
Tax & The Digital Economy
May 5th 2021 11:07 AM
A collection of the brief insights throughout March 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.
International Tax
May 4th 2021 06:26 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes:1) an article where our specialists reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
International Tax
May 4th 2021 07:44 AM
The United Nations, through its Committee of Experts on International Cooperation in Tax Matters, has approved recommended language for bilateral treaty rules to address taxing rights around income arising from Automated Digital Services (ADS). The new Article 12B and associated Commentary will form part of the 2021 version of the UN Model Tax Convention (MTC).
International Tax
May 4th 2021 03:59 PM
Digital Service Taxes, or DSTs, have been permeating the trade environment since 2018, but COVID-19 and the OECD’s digitalization of the economy project, commonly referred to as BEPS 2.0, have accelerated the focus on DSTs. The stated aim of DSTs is to ensure that “market” countries get increased taxing rights over the profits of tech-based multinational companies that sell into their local market, and collect data from and target advertisements at local audiences, regardless of their physical presence.
International Tax
May 4th 2021 12:43 PM
Welcome to the May edition of Australia's Monthly Tax Update, keeping you up to date on the latest Australian and international tax developments.
International Tax
April 27th 2021 08:13 AM
The Canadian Government’s budget was presented on 19 April 2021. The budget includes several international tax proposals but does not contain any proposed changes to the corporate tax rates in Canada.
International Tax
April 26th 2021 08:10 AM
The Deputy Prime Minister and Minister of Finance, Chrystia Freeland, presented Canada's budget on 19 April 2021. This Tax Insights discusses the tax initiatives announced.
International Tax
April 23rd 2021 04:40 PM
Australia’s hybrid mismatch rules include ‘imported mismatch’ rules, which may apply more broadly than OECD BEPS Action 2-compliant hybrid rules implemented in other countries. On April 21, the Australian Taxation Office (ATO) released a draft practical compliance guideline, which provides guidance on how taxpayers practically should apply the imported mismatch rule and what documentation is required.
International Tax
April 23rd 2021 09:57 AM
The Comptroller has submitted significant proposed amendments to Texas Admin Code Sec. 3.599, concerning the research and development activities franchise tax credit. The publication triggers a 30-day period of public commentary. The earliest date of adoption is May 16, 2021.
International Tax
April 22nd 2021 07:37 AM
In this article first published in Tax Journal, our specialists reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape.
International Tax
April 22nd 2021 08:05 AM
The Mexican Senate approved legislation on April 20 that will modify the tax and labor law treatment of subcontracted services in Mexico. These law reforms may result in significant financial impacts to Mexican investments, as well as human resource considerations.
International Tax
April 21st 2021 04:26 PM
The Taxation (Annual Rates for 2020-21, Feasibility Expenditure and Remedial Matters) Act has been enacted and is now in force. In this PwC news alert, we consider the amendments arising from the Finance and Expenditure Select Committee’s recommendations following the submissions process, and we also discuss new measures that were introduced by way of a supplementary order paper (SOP).
International Tax
April 19th 2021 04:55 PM
Highlights of this edition include: 1) Webcast - Using tax incentives to generate value from investments; 2) Tax Readiness webcast: Are digital taxes here to stay? 3) US Senate Finance Democrats and Treasury Secretary Yellen call for international tax policy changes; and 4) The latest podcast in our Tap into Tax series - Catching the international tax policy train.
International Tax
April 19th 2021 11:04 AM
Watch the replay from this webcast held on Wednesday, 5 May 2021 to learn more about environmental, social and governance (ESG) and how tax leaders can engage with the C-suite to align tax with ESG transformation.
International Tax
April 19th 2021 09:40 AM
This edition includes: 1) MOEF announces tax expenditure plan for 2021; 2) MOEF announces measures to combat real estate speculation; 3) NTS launches Task force to establish income data management system; 4) Notes to corporate local income tax return filing by April 30; and 5) Rulings update.
International Tax
April 14th 2021 01:22 PM
Under Section 274(n), a taxpayer generally may deduct only 50% of the taxpayer’s otherwise allowable business expenses for food and beverages. The Consolidated Appropriations Act, 2021, removed this limitation for business expenses paid or incurred after 2020 and before 2023 for food or beverages provided by a restaurant. The IRS has released Notice 2021-25, which provides guidance on what is a ‘restaurant’ for this purpose.
International Tax
April 13th 2021 03:54 PM
PwC has welcomed the opportunity to share its views on the consultation document on the Digital levy which aims to provide COVID-19 recovery resources for the European Union.
Real Estate
April 13th 2021 11:22 AM
In October 2019, the German coalition government issued a joint press release announcing that the proposed reforms to the German Real Estate Transfer Tax Act (RETTA) would be delayed until the first half of 2020. At that time, the parties failed to reach a solution in the first half of 2020 and progress had since halted. Efforts have now started to adopt the original draft with few amendments despite the requests for changes.
International Tax
April 6th 2021 05:40 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This edition includes: 1) our “Doing business and investing in the UK'' guide, providing insight into the key aspects of business expansion, from establishing an entity to navigating employment legislation; 2) latest US tax developments.
Tax & The Digital Economy
April 6th 2021 04:54 PM
A collection of the brief insights throughout March 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.
Tax & The Digital Economy
April 6th 2021 03:14 PM
The United States Trade Representative (USTR) recently published updates to digital service tax (DST) investigations regarding Austria, India, Italy, Spain, Turkey, the UK, Brazil, the Czech Republic, the EU, and Indonesia. The USTR has terminated its investigations regarding Brazil, the Czech Republic, the EU, and Indonesia because those jurisdictions either have not adopted or not implemented a DST during the period of investigation. For the other countries, the investigatory process is continuing, and the USTR has proposed a list of goods for potential tariffs.
International Tax
April 6th 2021 10:22 AM
Building off President Biden’s recent proposals for infrastructure spending to be paid for with corporate tax increases, Senate Finance Committee Chairman Ron Wyden (D-OR) joined with Finance members Sherrod Brown (D-OH) and Mark Warner (D-VA) in releasing a nine-page paper outlining a framework for overhauling US international tax policy. In a separate event, Treasury Secretary Janet Yellen highlighted the tax proposals announced last week by President Biden that call for increasing the US minimum rate on global income and increasing the US corporate tax rate to 28%.
International Tax
April 6th 2021 09:38 AM
President Joe Biden on March 31 announced a $2 trillion "American Jobs Plan" focused on infrastructure and other spending initiatives, including tax incentives for clean energy and domestic manufacturing. He also proposed a 'Made in America Tax Plan' containing corporate tax increase proposals designed to offset the costs of the American Jobs Plan infrastructure spending. In advance of the President’s remarks, the White House released an outline of specific infrastructure proposals and corporate tax increase offsets. This PwC Insight focuses on the tax-related aspects of President Biden’s plan related to environmental, social, and governance (ESG) issues.
International Tax
April 1st 2021 10:49 AM
On March 25, 2021, the Bill introducing a conditional withholding tax on dividends was submitted to the Lower House of Parliament. The Conditional Withholding Tax on Dividends Act supplements the 2021 Withholding Tax Act and aims to prevent the untaxed flow of dividends from the Netherlands to low-tax jurisdictions and in abuse situations.
International Tax
April 1st 2021 10:42 AM
Welcome to our latest EUDTG bimonthly newsletter, featuring summaries of all the relevant ECJ and national court cases and decisions, and EU policy initiatives related to EU direct tax law and state aid.
International Tax
April 1st 2021 10:54 AM
On 29 March 2021 the Dutch Ministry of Finance published a consultation document which includes proposed amendments to the Dutch qualification rules for Dutch and foreign entities. The consultation period ends on 26 April 2021.
International Tax
April 1st 2021 07:45 AM
President Joe Biden held an event in Pittsburgh on 31 March 2021 to announce a $2 trillion "American Jobs Plan'' focused on infrastructure and other spending initiatives, with part of the cost of his proposals to be offset by corporate tax increase proposals. In advance of the President’s remarks, the White House released an outline of specific infrastructure proposals and corporate tax increase offsets.
International Tax
April 1st 2021 08:06 AM
Welcome to the April edition of Australia's Monthly Tax Update, keeping you up to date on the latest Australian and international tax developments.
International Tax
March 31st 2021 04:30 PM
The Cyprus Parliament recently approved the draft Bill amending the Law on Administrative Cooperation in the Field of Taxation, implementing DAC6.
International Tax
March 31st 2021 04:13 PM
Have you updated your approach to allocating and apportioning stewardship expense? Join this webcast on Wednesday, 7 April at 7pm and hear from our international tax and transfer pricing specialists.
International Tax
March 31st 2021 11:10 AM
Global trade will play a key role in economic recovery efforts in the United States and around the world. Business supply chains continue to be affected by the implementation of the updated free trade agreements in Canada and Mexico. The Biden administration is expected to continue negotiating separate free trade agreements with the European Union and the United Kingdom, as well as pursuing new trade agreements with other nations.
International Tax
March 31st 2021 10:36 AM
The Finance Bill 2021 was passed by the Lok Sabha on 23 March 2021 with amendments to the original Bill that was tabled before the Lok Sabha on 1 February 2021 (Original Bill). Subsequently, the Bill was affirmed by the Rajya Sabha on 24 March 2021, without any further amendments. This Tax Insight explains the key amendments.
International Tax
March 30th 2021 08:19 AM
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments.
International Tax
March 29th 2021 08:32 AM
The Spanish government on March 9 amended the Corporate Income Tax law and the Non-Resident Income Tax law to address hybrid mismatches. The stated purpose of these amendments is to enact into Spanish domestic law the anti-hybrid rules included in EU Directive 2016/1164, dated July 12, 2016 (‘ATAD 1), as amended by EU Directive 2017/952, dated May 29, 2017 (ATAD 2).
International Tax
March 26th 2021 02:05 PM
The German government on March 24 passed a draft bill (Draft) aimed at implementing the Anti-Tax Avoidance Directive (ATAD). The Draft is expected to become law before the September elections.
International Tax
March 26th 2021 07:59 AM
The Senate Finance Committee on March 25 2021 held a hearing on how US international tax policy impacts American workers, jobs, and investment.
International Tax
March 25th 2021 09:47 AM
The Council of the European Union has adopted an EU Directive expanding the scope of automatic exchange of information to digital platform operators and amending existing provisions on administrative cooperation in the field of taxation (“DAC7”). DAC7 introduces the 6th amendment to the Directive 2011/16/EU on administrative cooperation in the field of taxation (“DAC”).
Transfer Pricing
March 24th 2021 08:47 AM
While EU Member States, advisors and taxpayers are still navigating the DAC6 landscape, the European Union is moving quickly to expand reporting obligations in the digital world. On March 10, the European Parliament (EP) adopted the DAC7 text featuring the new digital platform reporting rules proposed last year by the EU Commission. On March 22, the EU Council adopted the new rules, applicable January 1, 2023. Separately on March 10, the Commission launched a public consultation on DAC8, which would impose reporting obligations for e-money and crypto assets.
International Tax
March 24th 2021 11:11 AM
The American Rescue Plan Act enacted on March 11 provides over $195 billion in direct aid to states but includes a provision prohibiting the use of those funds to “either directly or indirectly offset a reduction in the net tax revenue” of a receiving state. Businesses should monitor tax measures potentially impacted by this provision and the status of Treasury guidance on the issue.
International Tax
March 22nd 2021 03:26 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This edition includes measures announced in the Finance Bill.
International Tax
March 22nd 2021 02:33 PM
The Inland Revenue (Amendment) (Miscellaneous Provisions) Bill 2021 was recently gazetted. The Bill, among other things, seeks to amend the Inland Revenue Ordinance to enhance the deduction of foreign taxes for profits tax purposes as a means for relieving double taxation in Hong Kong. Upon enactment of the Bill, the revised rules on foreign tax deduction will take effect from the year of assessment 2021/22.
International Tax
March 22nd 2021 02:26 PM
The Cypriot Ministry of Finance has submitted two tax bills to Parliament proposing anti-tax abuse measures in line with recent EU Country-Specific Recommendations for Cyprus and the EU guidelines for defensive tax measures to be adopted by EU Member States towards EU blacklisted jurisdictions.
International Tax
March 18th 2021 05:37 PM
The Court of Justice of the European Union has issued its judgments in two cases relating to the Hungarian Advertisement tax and to the Polish retail tax ruling that they do not infringe EU State aid rules.
International Tax
March 18th 2021 12:55 PM
This edition includes: 1) The National Assembly approved Bill to amend the Special Tax Treatment Control Law; 2) Amended Enforcement Rules of Tax Laws have been proclaimed; 3) NTS expands the ‘Advance Verification for R&D Tax Credit’; and 4) Rulings update.
International Tax
March 17th 2021 12:49 PM
Interest limitation rules ("ILR"), as required by the EU Anti Tax Avoidance Directive, are set to be transposed into Irish law later this year and take effect from 1 January 2022. The existing Irish interest deductibility rules will remain in effect after 1 January 2022 and taxpayers will need to compute tax liabilities by reference to the new ILR and the old deductibility rules. The Department of Finance acknowledges the complexity that will ensue and has sought stakeholder engagement by way of a Feedback Statement process. The first part of this process closed for public comments on 8 March 2021.
Tax & The Digital Economy
March 17th 2021 07:51 AM
The Maryland Comptroller has issued guidance on the expansion of the state’s sales and use tax to a digital product or code, specifying which items are considered taxable digital products if delivered electronically, explaining exclusions and exemptions from tax, and applying economic nexus and marketplace facilitator rules to digital products. The tax must be collected beginning March 14, 2021. The Comptroller has provided an extension to July 15, 2021 to file and pay tax, and relief from interest and penalties if the tax is paid by that date. The requirement to collect the tax from customers has not been delayed.
Tax & The Digital Economy
March 16th 2021 11:33 AM
In a time when information is key and compliance is vital, GlobalDigitalTaxOnline (GDTO) is an essential tool to help navigate the complex world of tax and the reporting of various digital/electronic services.
International Tax
March 16th 2021 08:07 AM
Finance Bill 2021 has now been published and it includes several legislative updates to the anti-hybrid rules following HMRCs recent consultation. This article provides a high level summary of these updates.
International Tax
March 12th 2021 08:10 AM
The EU Member States’ negotiating mandate on public country-by-country reporting (public CbCR) was established under the Portuguese Presidency of the Council on the basis of its compromise draft following the informal Council video conference on 25 February 2021. The mandate also was approved by Member State permanent representatives in the ‘Coreper’ meeting on 3 March 2021.
International Tax
March 15th 2021 08:17 AM
Most of the EU Member States that deferred the DAC6 reporting deadlines due to the pandemic postponed them to February 28, 2021. Thus, the extended deadline for reporting cross-border arrangements satisfying at least one of the DAC6 hallmarks and whose first step was implemented on or after June 25, 2018 has passed.
International Tax
March 15th 2021 11:01 AM
This edition of Tax Tips provides a recap of the New Zealand Government's COVID-19 support measures and also discusses the NZ Inland Revenue's new exposure draft on the administration of the imported hybrid mismatch rule, which sets out the steps Inland Revenue expects taxpayers to have undertaken before claiming deductions for cross-border related party payments.
International Tax
March 11th 2021 08:42 AM
The House on March 10 voted 220 to 211 to approve the Senate-passed version of H.R. 1319, the American Rescue Plan Act of 2021. House passage of the $1.9 trillion legislative package clears the measure to go to the White House and be signed into law by President Biden.
International Tax
March 10th 2021 09:41 AM
The Biden Administration and Congress are focused on responding to the COVID-19 pandemic and its economic impact, while also preparing to consider significant tax law changes impacting business and individuals. Important changes in trade policy also are likely. Foreign companies and investors will need to engage early with policymakers to educate them about the vital role they play in the US economy and about their unique concerns.
International Tax
March 9th 2021 10:07 AM
Following the challenging economic climate of 2020 and the change of presidential administrations in January, 2021 is shaping up as a crucial year for foreign direct investment (FDI) in the United States. There are several key trends and points worth noting.
International Tax
March 9th 2021 08:17 AM
The Senate on March 6 passed by a vote of 50 to 49 a Senate substitute amendment to the COVID relief legislation that made certain changes to the House-passed budget reconciliation bill (H.R. 1319, the American Rescue Plan Act of 2021). The final vote came Saturday afternoon after an all-night session in which a number of additional amendments were considered.
International Tax
March 8th 2021 02:11 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This edition includes our comments on the Chancellor's recent Budget.
International Tax
March 8th 2021 10:54 AM
The Swiss Federal Tax Administration recently published two circulars outlining the safe harbour interest rates applicable to shareholder and intercompany loans, denominated in Swiss Francs and foreign currencies, applicable for 2021.
International Tax
March 5th 2021 02:00 PM
The Wisconsin Court of Appeals on February 25 upheld a lower court decision concluding that Wisconsin’s dividend received deduction (DRD) - which requires that a distribution be received with respect to ‘common stock’ - applies to a distribution made from a foreign LLP that elected to be taxed as a corporation for federal income tax purposes.
International Tax
March 3rd 2021 07:07 PM
The Chancellor delivered his 2021 Budget on 3 March 2021. Set out in this article is a summary of the key announcements from an international corporate tax and treasury perspective for multinational companies.
International Tax
March 1st 2021 09:24 AM
On 24 April 2019, the French Supreme Administrative Court asked for a preliminary ruling on the Société Générale case (C-403/19) to the Court of Justice of the European Union (CJEU). The CJEU delivered its Judgment on 25 February 2021 without any Advocate General’s opinion.
International Tax
March 2nd 2021 11:01 AM
During an informal video conference on 25 February 2021, a majority of EU Member States (through their Ministers of Internal Market and Industry) expressed support for the compromise text of a proposed Directive on public country-by-country reporting (pCbCR). The disclosure of certain tax information by undertakings and branches is now supported by 15 Member States, including the current Presidency (Portugal) as a non-tax matter that requires a ‘qualified majority’ of votes to proceed.
International Tax
February 26th 2021 03:06 PM
Register to join us on Wednesday, 17 March 2021 at 6pm to discuss international tax planning in a post-election environment.
International Tax
March 3rd 2021 10:22 AM
Welcome to the March edition of Australia's Monthly Tax Update, keeping you up to date on the latest Australian and international tax developments.
International Tax
March 3rd 2021 08:57 AM
US State and local budget processes were significantly disrupted by the impact of COVID-19. States and localities now confront difficult tax and budget choices in the current and upcoming legislative sessions.
International Tax
March 2nd 2021 02:04 PM
The Pennsylvania Department of Revenue has announced a 90-day voluntary compliance program to run until May 8, 2021, which allows any business that has inventory or stores property in the state but that is not registered to collect and pay Pennsylvania taxes to become compliant. The program offers a limited look-back period and penalty relief.
International Tax
February 25th 2021 04:29 PM
China recently released the Foreign Investments Security Review Measures which require foreign investors to pass certain reviews from the perspective of national security when investing in specific areas and industries in China. The Measures came into force on 18 January 2021 and have major and material impacts on certain foreign investment projects and transactions. Watch this recent webcast where the key issues that foreign investors may face after the Measures are enacted, and the resulting business impacts were discussed.
International Tax
February 24th 2021 10:40 AM
The German Ministry of Finance has issued a circular that provides updated filing and withholding procedures for royalties attributable to IP registered in a German book or register. By taking advantage of this new simplified process within the prescribed time limits, taxpayers have an opportunity to avoid penalties that may otherwise be imposed.
International Tax
February 24th 2021 08:56 AM
The German Federal Ministry of Finance recently published a draft bill for a so-called "Tax Haven Defence Act", which provides for the implementation of defence measures in regard to business relationships or shareholdings with reference to certain non-cooperative states.
International Tax
February 22nd 2021 03:55 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Topics covered include Budget 2021 and details of our live session taking place on 4 March where we will explore the latest tax issues and how they will impact businesses.
International Tax
February 22nd 2021 10:29 AM
We expect several state and local tax trends to impact US inbound companies in 2021. These trends include: 1) President Biden’s tax proposals and continued conformity; 2) an increase in state and local taxation, specifically at the local level; 3) enhanced state focus on transfer pricing; 4) greater opportunity for tax credits and incentives changes in consumption taxes; and 5) telecommuting nexus. Inbound companies should evaluate their US state tax exposure risk and determine whether the anticipated changes in 2021 could have a material effect on such exposure.
International Tax
February 19th 2021 01:03 PM
The Indian Finance Minister recently presented the Union Budget 2021 against the backdrop of a challenging economic environment due to COVID-19. In view of India’s tax reform measures to date, Budget 2021 maintains the same overall tax structure, but contains several measures that aim to attain tax certainty, facilitate tax administration, and reduce tax disputes. Multinational entities should analyze the impact of key Budget proposals on their operations, including a helpful provision to create a new board for advance rulings.
International Tax
February 18th 2021 10:34 AM
The latest edition of our Korean tax update.
International Tax
February 8th 2021 02:02 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Topics include taxation of the digital economy and Germany's withholding tax proposals.
International Tax
January 25th 2021 04:46 PM
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Topics include: 1) revised OECD guidance on tax treaty interpretation during the COVID-19 pandemic; 2) US election analysis - what it means for US and global tax policy; and 3) Global business operating models.
International Tax
January 11th 2021 04:35 PM
Welcome to our first edition for 2021 of recent developments in international and treasury tax of interest to multinationals operating in the UK.
International Tax
December 14th 2020 03:19 PM
Welcome to our last update for 2020 on recent developments in international and treasury tax of interest to multinationals operating in the UK.
US Tax Reform
December 12th 2017 10:21 AM
US Tax Reform could give rise to sweeping, complex changes for companies with a US footprint. To help you stay informed, we'll be updating this hub with all the latest comments and analysis as the situation develops.
