International review for August 2021

Tim Sarson’s latest summary of international developments.

Tim Sarson’s latest summary of international developments.

Tax never takes a holiday and, as such, July and August were full of new developments. Beginning in the United States, new competent authority agreements provided welcome clarifications on the US-UK double tax treaty, as well as a legislative instrument which may pave the way for a simple Senate majority to pass Biden’s ambitious tax reforms. The OECD meanwhile made useful updates to their transfer pricing country profiles and approved new outcomes in respect of their work in combatting harmful tax practices. The COVID-19 pandemic and its associated tax measures continued to evolve – multinational businesses, in particular, should closely monitor changes bearing in mind that as restrictions are lifted support measures may be withdrawn. Finally, in India, a judgment allowing a Swiss taxpayer to carry forward a capital loss illustrates that the determination of whether a transaction is genuine or done for a tax avoidance purpose is a fact-based exercise.

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

  • US-UK competent authority agreements.
  • US tax reform.
  • OECD transfer pricing country profiles.
  • COVID-19 tax responses.
  • A judgment in India allowing a capital loss on sale of shares.

* First published by Tax Journal on 2 September 2021. Reproduced with permission.

Tim Sarson

Partner, UK Head of Tax Policy

KPMG in the UK