International review for May 2021

In May, the US followed the EU’s lead in taking its first steps towards the introduction of public Country by Country reporting. There were signs of members of the European Parliament becoming impatient in waiting for a global agreement on taxing the digital economy, with a resolution on a temporary EU digital services tax. The European Commission also put forward a bold new vision for EU tax policy. Companies should re-evaluate the permanent establishment and residence risks in relation to cross-border workers still working from home as government restrictions begin to lift. Recent judgments in the EU and India may have implications for multinationals. In Taiwan, there was an update on rules allowing a one-time transfer pricing adjustment before the year-end for companies engaged in certain controlled transactions.

In the latest of his regular articles for Tax Journal*, Tim Sarson looks back at some of the interesting developments that unfolded in May in the international tax arena. This article includes updates on the following:

• Public country by country reporting;
• The OECD’s International Compliance Assurance Programme (ICAP);
• The EU’s tax agenda;
• Risks for home workers: permanent establishments and corporate tax residence;
• Recent notable tax cases; and
• New transfer pricing guidance in Taiwan.

* First published by Tax Journal on 28 May 2021. Reproduced with permission.

For further information please contact :

• Tim Sarson