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Mark R. Martin

Mark R. Martin

Principal in charge of WNT Tax Controversy & Dispute Resolution Services, KPMG in the U.S.

Recent Articles

July 2024

23 Jul - EU: VAT intermediation rules not applicable if underlying transaction is not an economic activity (CJEU judgment)

23 Jul - Korea: Royalties received for use of domestically unregistered patents subject to withholding tax under U.S. treaty (Tax Tribunal decision)

23 Jul - KPMG report: European VAT cases—expert insights and business implications

23 Jul - Monaco: New penalties under CRS regime

23 Jul - Monaco: Updated AEOI guidance under CRS regime

23 Jul - United States: Gain recognized on sale of partnership interest attributable to inventory not U.S.-source income subject to U.S. tax; Tax Court reversed

22 Jul - Australia: Application of taxation of financial arrangement rules to earn-outs (Federal Court decision)

22 Jul - Canada: Digital platforms must report seller information by 31 January 2025

22 Jul - KPMG report: APMA program annual report on APA statistics in the United States for 2023

22 Jul - KPMG report: Employee data reporting under Pillar Two

22 Jul - United States: IRS provides tax relief for taxpayers in Texas affected by Hurricane Beryl

22 Jul - United States: Percentage depletion for oil and gas produced from marginal properties for 2024

22 Jul - United States: Texas (sales tax on credit card processing fees); Wisconsin (unclaimed property voluntary disclosure); multistate (digital advertising tax updates)

19 Jul - United States: CBP adjusts customs user fees for inflation (FY 2025)

19 Jul - Greece: Guidance on deductibility of commitment fees paid to banks for provision of credit

18 Jul - Australia: Updated ATO advice on R&D tax transparency reporting

18 Jul - Canada: Only Federal Court can review discretionary decisions of tax authority in transfer pricing matters (Supreme Court decision)

18 Jul - Czech Republic: Statutory representative held liable for corporation’s tax arrears (Supreme Administrative Court decision)

18 Jul - OECD: Selection documentation package requirements for International Compliance Assurance Programme (ICAP)

18 Jul - Tanzania: Waiver of late fees for company documents

18 Jul - UK: Activities qualified for R&D tax credits (First-tier Tribunal decision)

18 Jul - UK: Adviser fees on disposal of subsidiary business not deductible as management expenses (Supreme Court decision)

17 Jul - Poland: New consultations on e-invoicing system (KSeF)

17 Jul - Poland: Reimbursement of costs for private car and subsidies under incentive funds are taxable (Supreme Administrative Court decisions)

16 Jul - Hong Kong: Stamp duty group relief only available to associated companies with issued share capital (Court of Appeal decision)

16 Jul - Mexico: New requirements for registering foreign digital service providers

16 Jul - Mexico: Tax administration challenging deductibility, VAT credits for advertising and promotional expenses

16 Jul - OECD: Negotiations on Pillar One multilateral convention continue

15 Jul - United States: Florida (sourcing rule for intangible property); New Jersey (new corporate transit fee); Oregon (proposed increase in corporate minimum tax); Pennsylvania (increase in NOL carryforward limitation)

12 Jul - Canada: Updated list of imported goods targeted for potential audits

12 Jul - UAE: Deadline to file FATCA and CRS reports is now 15 July 2024

12 Jul - United States: Final regulations on information reporting on digital asset transactions

11 Jul - United States: Certain basket contract transactions identified as listed transactions

11 Jul - United States: IRS provides tax relief for taxpayers affected by storms, flooding, landslides, and mudslides in West Virginia

11 Jul - India: Portion of service fee from single contract attributable to PE taxable in India (High Court decision)

11 Jul - Israel: Adjusted intellectual property (IP) valuation (District Court decision)

11 Jul - KPMG report: Transfer pricing in Brazil

11 Jul - Malaysia: New voluntary disclosure program

11 Jul - Poland: Comprehensive performance and VAT; lump-sum income tax; transfer of organized part of enterprise not subject to VAT (Supreme Administrative Court decisions)

11 Jul - Spain: Deadline to claim VAT refunds for 2023 is 30 September 2024

10 Jul - Chile: Updated invoice and document requirements for VAT

10 Jul - Czech Republic: Acquisition structure not abusive; cost base when applying net profit margin transfer pricing method (Supreme Administrative Court decisions)

10 Jul - EU: Update on direct tax initiatives, including BEPS 2.0, “Unshell,” SAFE, BEFIT, DEBRA, transfer pricing, public country-by-country reporting, FASTER, DAC7, DAC8

10 Jul - Pakistan: Withholding tax collection rates for tax year 2025

10 Jul - Saudi Arabia: E-invoicing requirement extended to 13th group of taxpayers from January 2025

10 Jul - United States: BIS issues guidance on export diversion risks

10 Jul - United States: IRS issues FAQs regarding registration for clean fuel production credit

10 Jul - Australia: ATO to collect data from online selling platforms

9 Jul - Australia: Changes to non-arm’s length income provisions for superannuation funds

9 Jul - Australia: Guidance on changes to income tax reporting for trustees and trust beneficiaries

8 Jul - UK: HMRC 2022-2023 tax gap report

8 Jul - UK: Interaction of succession rules and special oil taxation regime (First-tier Tribunal decision)

8 Jul - UK: Scope of “imported loss” rule (First-tier Tribunal decision)

8 Jul - United States: Application of BBA centralized partnership audit regime

8 Jul - United States: IRS rewards credit card banks with earlier deductions

5 Jul - United States: IRS steps up enforcement of the individual expatriation tax

3 Jul - Australia: Functional currency realization events on certain loan repayments

3 Jul - Malaysia: Updated e-invoice guidelines and FAQs

3 Jul - Spain: Guidance on deductibility of insurance technical reserves for corporate income tax purposes

3 Jul - United States: Guidance on procedural requirements for section 5000D excise tax on sales of “designated drugs”

3 Jul - United States: Inconsistency in state conformity to the Code

3 Jul - United States: Recent litigation regarding sales tax collection and remittance obligations in Illinois

2 Jul - United States: Reporting and paying the stock repurchase excise tax

2 Jul - United States: Procedures for obtaining automatic consent to change methods of accounting to the Allowance Charge-off Method

2 Jul - Australia: ATO guidance on small business incentives

2 Jul - Australia: Legislation on taxation of general insurers receives Royal Assent, ATO guidance released

2 Jul - Belgium: Extended deadline for GloBE registration for groups not intending to prepay to 16 September 2024

2 Jul - Italy: Changes to VAT penalties effective 1 September 2024

2 Jul - Saudi Arabia: Penalty waiver for taxes, including VAT and excise tax, extended through December 2024

2 Jul - United States: Clean fuel production credit—a new incentive regime

2 Jul - United States: Specified research and experimentation expenditures under section 174

1 Jul - Australia: ATO update on implementation of Pillar Two global minimum tax rules

1 Jul - KPMG report: Taxpayer-initiated transfer pricing adjustments in MAP

1 Jul - KPMG report: Impact of e-invoicing mandates on intercompany transactions

1 Jul - KPMG report: VAT remote-seller rules

1 Jul - United States: Amended guidance regarding payment of tax by commercially acceptable means

1 Jul - United States: Recapture of interest on erroneous refunds of COVID-19 relief employment tax credits

1 Jul - United States: Reference price for section 45I credit for production of natural gas from marginal wells

1 Jul - Vietnam: Extended deadlines for payment of corporate and individual income tax, VAT, land rental fee, special consumption tax for automobiles

June 2024

28 Jun - Argentina: Extension of FATCA and CRS deadline

28 Jun - Cyprus: Extended deadline for individual income tax returns for 2023

28 Jun - Finland: Public country-by-country reporting implemented

28 Jun - Malta: Public country-by-country reporting implemented

28 Jun - United States: Chevron overruled (U.S. Supreme Court)

28 Jun - United States: Durable medical equipment sales and use tax exemption prospectively invalidated (Supreme Court decision)

27 Jun - United States: IRS provides tax relief for taxpayers affected by storms, flooding, winds, and tornadoes in Iowa

27 Jun - United States: IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in southern Mississippi

27 Jun - United States: Treasury and IRS guidance on partnership “basis shifting” transactions

27 Jun - Mexico: Special tax on production and services not includible in VAT base (court decision)

27 Jun - Spain: Broader interpretation of industrial activity for purposes of reduced excise duty on electricity (Supreme Court decision)

27 Jun - Australia: Updated advice on waiver of 2020-2021, 2021-2022 payroll taxes for eligible employers (Victoria)

26 Jun - Australia: Guidance on when tax authority may disregard operation of “Division 7A”

26 Jun - Australia: Taxpayer not liable for withholding tax on embedded royalties or subject to DPT (Full Federal Court decision)

26 Jun - Poland: Tax-exempt rental income of family foundations; transfer pricing documentation required with lump-sum taxation; partnership liquidation subject to VAT (court decisions)

26 Jun - United States: Italian company agrees to pay $538,000 for violations of U.S. OFAC sanctions on North Korea

26 Jun - United States: National Taxpayer Advocate mid-year report to Congress

26 Jun - United States: Third quarter update to IRS 2023-2024 Priority Guidance Plan

26 Jun - United States: IRS provides tax relief for taxpayers affected by fires and flooding in New Mexico

25 Jun - United States: IRS provides tax relief for taxpayers affected by storms and tornadoes in Florida

25 Jun - United States: IRS provides tax relief for taxpayers affected by storms, tornadoes, and flooding in Oklahoma

25 Jun - United States: University settles export control violations related to genetically modified fruit flies

25 Jun - Australia: Guidance on claiming foreign resident capital gains withholding tax credit

25 Jun - Costa Rica: Guidance for VAT-exempt taxpayers

25 Jun - Romania: New regulation expands e-invoicing mandate to B2C transactions

24 Jun - Italy: Guidance on cooperative compliance regime

24 Jun - United States: Arkansas (reduced corporate income tax rate); Oklahoma (sales and use tax exemption for digital assets mining equipment); Vermont (taxation of remotely accessed software)

24 Jun - United States: IRS’s denial of tax-exempt status upheld (D.C. Circuit)

21 Jun - United States: Clean hydrogen production credit under section 45V, inflation adjustment factors and applicable amounts for 2023 and 2024

21 Jun - United States: Guidance on exceptions to 10% additional tax on early retirement plan distributions

21 Jun - United States: IRS releases revised draft Form 6765, Credit for Increasing Research Activities

21 Jun - United States: IRS provides enhanced access to Form 990 series data

21 Jun - Barbados: AEOI portal re-open for prior year submissions beginning 1 August 2024

20 Jun - KPMG report: Further guidance on Pillar Two GloBE model rules

20 Jun - KPMG report: New Amount B guidance expands on definitions

20 Jun - UK: Reflection of withholding tax risk in pricing of securities transactions not treaty anti-avoidance (Upper Tribunal decision)

20 Jun - United States: Mandatory repatriation tax under section 965 held constitutional (U.S. Supreme Court)

18 Jun - Australia: ATO clarifies “working from home” compliance guidance

18 Jun - KPMG report: OECD unveils further details on Amount B simplified approach

18 Jun - United States: Treasury announces suspension, by mutual agreement, of the Russia income tax treaty

17 Jun - United States: California (tax measures in budget legislation); Rhode Island (single-sales factor apportionment); South Carolina (sales tax on installed materials)

17 Jun - United States: IRS issues FAQs regarding educational assistance programs

17 Jun - United States: Treasury and IRS release guidance on partnership “basis shifting” transactions

17 Jun - EU: Toll manufacturer does not constitute a fixed establishment for VAT purposes (CJEU judgment)

17 Jun - India: General anti-avoidance rule may apply even if not within scope of specific anti-avoidance rule (High Court decision)

17 Jun - Japan: Updated CRS FAQs for automatic exchange of information process for nonresidents

14 Jun - Cyprus: Extended deadline for payment of central body for equal burden sharing fee on transfers of real estate, shares

14 Jun - KPMG report: Mexico’s general anti-abuse rule does not apply retroactively (Federal Tax Court decision)

13 Jun - United States: Additional limited relief from underpayment of estimated tax attributable to CAMT liability

13 Jun - United States: BIS imposes $285,000 penalty to resolve violations of unlicensed reexports to Russia by Turkish aviation company

12 Jun - United States: Section 45Y clean electricity production credit and section 48E clean electricity investment credit proposed regulations

12 Jun - United States: IRS provides tax relief for taxpayers affected by storms in Arkansas

12 Jun - United States: IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas (updated)

11 Jun - Ireland: Arm’s length price of services charged by subsidiary to parent must include cost of employee share awards (Tax Appeals Commission decision)

11 Jun - South Africa: 2024 tax filing deadlines for individuals

11 Jun - Cyprus: Quality assurance review template for Local file

11 Jun - Netherlands: “Box 3” (wealth tax) regime also contrary to EU law because flat-rate returns still in use (Supreme Court decision)

11 Jun - Poland: Foundation grants not charged into VAT base; UK pension benefits not exempt; financing fees fully includible; real estate tax base (Supreme Administrative Court decisions)

11 Jun - Poland: Postponement of e-invoicing mandate signed by president

10 Jun - United States: Connecticut (unclaimed loss carryforward period, unclaimed property modifications); Florida (unclaimed property law changes); South Carolina (income producing activities)

10 Jun - United States: IRS adds new FAQs to provide guidance to qualified intermediaries (QIs)

10 Jun - United States: Lower of cost or market (IRS practice unit)

7 Jun - United States: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2024

7 Jun - United States: Guidance for the energy community bonus credit under "Inflation Reduction Act"

7 Jun - United States: IRS provides tax relief for taxpayers affected by storms in Kentucky and West Virginia

7 Jun - United States: Procedures for qualified manufacturers, dealers and sellers of certain qualified clean vehicles under "Inflation Reduction Act"

7 Jun - Argentina: First automatic exchange of financial information under FATCA announced

7 Jun - India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)

6 Jun - Poland: Certain web services not subject to restrictions of corporate income tax law; settling costs of R&D activities (court decisions)

6 Jun - UK: Overview of employee share plan reporting, annual return filing deadline is 6 July 2024

6 Jun - United States: Estate tax value of stock is not reduced by contractual obligation to redeem shares (U.S. Supreme Court)

6 Jun - United States: IRS announces tax relief for taxpayers in Iowa affected by storms, tornadoes, and flooding

6 Jun - United States: IRS issues new FAQ for qualified intermediaries (QIs)

5 Jun - Cyprus: Tax treatment of premiums and medical plans

5 Jun - EU: Formal notices sent to member states for failure to exchange information required under DAC7

5 Jun - India: Guarantee charges received by foreign company not considered “interest,” taxable as “other income” (High Court decision)

5 Jun - OECD: Updated International Compliance Assurance Programme (ICAP) FAQs

5 Jun - Oman: CRS reporting deadline extended to 30 June 2024

5 Jun - Serbia: Rulebook on arm’s length interest rates for 2024

5 Jun - United States: Treatment of certain relief payments made to individuals affected by East Palestine, Ohio train derailment

4 Jun - United States: IRS violated APA notice and comment procedures in issuing Notice 2017-10 (Eleventh Circuit)

4 Jun - Colombia: Increased e-invoicing audits

4 Jun - Greece: New code of tax procedures revises tax system

3 Jun - OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends

3 Jun - KPMG report: Assessing the impact of Amount B

3 Jun - Spain: Excise duty on hydrocarbons infringes EU Directive for taxation of energy products and electricity (CJEU judgment)

3 Jun - United States: IRS removal of automatic accounting methods

May 2024

31 May - United States: IRS provides tax relief for taxpayers in Massachusetts affected by severe storms, flooding

31 May - Hong Kong: List of common errors in AEOI reporting published

31 May - Panama: Guidance on registration, changes, and deactivation of entities on for FATCA and AEOI portal

30 May - India: Taxation of foreign branch at higher rate than applicable to domestic company not prevented by non-discrimination article of treaty (High Court decision)

30 May - Italy: Certain additional obligations on online service providers not allowed under EU law (CJEU judgment)

30 May - Poland: Intra-community VAT supply of construction materials; issuance of invoice for bad debt relief (court decisions)

30 May - Poland: Postponement of e-invoicing mandate and reporting obligations of digital platform operators (DAC7) passed by Parliament

30 May - Saudi Arabia: E-invoicing requirement extended to 12th group of taxpayers from December 1, 2024

30 May - United States: Polyoxymethylene added to Superfund list

29 May - Belgium: Due date for first GloBE registration is July 13, 2024

29 May - KPMG report: U.S. Tax Court decision interpreting section 7508A(d)’s automatic and mandatory extension for filing a petition

28 May - Bermuda: CRS reporting deadline is May 31, 2024

28 May - Cyprus: Final version of 2022 transfer pricing documentation form

28 May - Hungary: Rule requiring submission of information and documents for VAT refund claims within one month held contrary to EU law (CJEU judgment)

28 May - United States: IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas

24 May - India: Interest paid by permanent establishment to overseas head office not taxable under India-France treaty (tribunal decision)

24 May - Netherlands: Financial instrument treated as equity (Supreme Court decision)

24 May - United States: Prior guidance that certain requirements for tax-exempt status satisfied under state law obsoleted due to material change in law

23 May - KPMG report: Comments on consultation on UK tax administration framework

23 May - UK: Denial of R&D tax incentives upheld (First-tier Tribunal decision)

23 May - UK: HMRC guidance on registration under Pillar Two global minimum tax regime

22 May - United States: Further deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments

22 May - United States: Further extended phase-in provisions under section 871(m) regulations

22 May - United States: Option granted to related entity with respect to real property not a sham (U.S. Tax Court)

21 May - Australia: FY 2023-2024 income tax filing requirements

21 May - Australia: Guide on how to avoid unexpected tax consequences in relation to “Division 7A” loan repayments

21 May - France: Claim for cross-border loss relief denied (Supreme Administrative Court decision)

21 May - France: Taxation of assets held abroad (CJEU referral)

21 May - Poland: Excise duty on leased cars provided to employees; taxation of employee accommodation benefits; taxation of family foundation (court decisions)

20 May - Cyprus: Applications for reduced VAT rate on supply or construction of private dwelling must be submitted online beginning 27 May

20 May - Kenya: Gains on petroleum products not subject to additional import duties (High Court decision)

20 May - United States: IRS provides tax relief for taxpayers affected by storms and tornadoes in Iowa

20 May - United States: IRS provides tax relief for taxpayers affected by storms and tornadoes in Nebraska

20 May - United States: No change to list of countries cooperating with international boycott

20 May - United States: No gift tax liability following termination of marital trusts

17 May - United States: Capacity limitation carryover amounts for 2024 Low-Income Communities Bonus Credit program year

17 May - Australia: Tax promoter bill passes Parliament

16 May - Liechtenstein: Updated CRS guidance for AEOI

16 May - United States: IRS announces tax relief for taxpayers affected by tornadoes in Ohio

16 May - United States: Modified domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E, including new elective safe harbor

15 May - Canada: CBSA Assessment and Revenue Management (CARM) mandatory registration extended to October 2024

15 May - Czech Republic: Transfer prices for advertising expenses; statutory rate of interest on retained VAT deductions upheld (Supreme Administrative Court decisions)

15 May - Malaysia: Updated advance pricing arrangement guidelines

15 May - Poland: Taxable amount of in-kind contribution of property for VAT purposes is value of shares issued in exchange (CJEU judgment)

14 May - Costa Rica: Updated CRS procedures

14 May - United States: House Ways and Means to mark up bills relating to disclosure requirements and foreign donations and grants of tax-exempt organizations; JCT descriptions

13 May - United States: Application period for second year of environmental justice solar and wind capacity limitation program opening 28 May

13 May - United States: Colorado (combined reporting changes); Nevada (proposed changes for marketplace facilitators); Tennessee (franchise tax refunds)

10 May - United States: Accelerating Form 1099 deadlines, prioritizing taxpayer efficiency

10 May - United States: Congress passes one-week FAA extension

10 May - India: Cost of bonus shares is zero for purposes of computing capital gains (tribunal decision)

9 May - UK: Expenses allegedly for employee renumeration held not wholly and exclusively for trade purposes and thus not deductible (Upper Tribunal decisions)

9 May - UK: Property held to be purely residential and thus subject to higher stamp duty land tax rate (First-tier Tribunal decision)

9 May - United States: Interest rates, tax underpayments and overpayments remain same for third quarter 2024

8 May - Luxembourg: NACE code assigned investment funds upheld (Administrative Court of Appeal decision)

7 May - Bolivia: Changes to procedures for export tax refund requests with surety insurance policy on first demand

7 May - Czech Republic: Beneficial owner of royalties under tax treaty (Supreme Administrative Court decision)

7 May - India: Premium received on redemption of debentures is interest income, not capital gains (tribunal decision)

7 May - Hong Kong: Tax authority’s views on various issues relating to profits tax, including FSIE regime

7 May - UAE: Corporate tax guide on qualifying group relief

7 May - United States: Guidance on information reporting on transactions with foreign trusts and large foreign gifts and transactions with foreign trusts

6 May - Colombia: Guidance on application of the significant economic presence rule

6 May - Nigeria: Insurance companies subject to generally applicable excess dividend tax rule (Tax Appeal Tribunal decision)

6 May - United States: IRS announces tax relief for taxpayers in Oklahoma affected by severe weather

6 May - United States: Taxpayer’s research was “funded” and thus ineligible for research tax credits under section 41; Tax Court affirmed (Eighth Circuit)

3 May - United States: IRS issues FAQs regarding disaster relief related to retirement plans and IRAs

3 May - United States: Guidance on extensions to make certain exemption allocations and elections related to generation-skipping transfer tax

3 May - United States: IRS has statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471; Tax Court reversed (D.C. Circuit)

2 May - United States: IRS releases annual update to strategic operating plan

2 May - United States: Updated procedures for section 355 private letter rulings

April 2024

30 Apr - Slovakia: Guidelines on transfer pricing documentation for 2023

30 Apr - United States: Updated annual list of automatic accounting method changes

29 Apr - OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy

29 Apr - United States: Announcement of 2024 allocation round and updated guidance on qualifying advanced energy project credit under section 48C(e)

29 Apr - United States: Alabama (additional sales tax on adult websites); Arkansas (sales tax on sightseeing flights); Colorado (no sales tax on streaming services); South Carolina (admissions tax on parasailing); Tennessee (franchise tax changes); Virginia (corporate income tax related-party expense disallowance rules)

26 Apr - United States: Franchise tax refund agreement reached (Tennessee)

26 Apr - Poland: New deadlines for e-invoicing mandate announced

26 Apr - Cyprus: Temporary zero VAT on specific goods extended to 30 June 2024

26 Apr - Czech Republic: Draft bill implementing directive on tax transparency rules for service providers facilitating cryptoasset transactions (DAC8)

26 Apr - EU: European Parliament adopts resolution on transfer pricing directive

25 Apr - Bolivia: “Eleventh group of taxpayers” to implement online billing modality

25 Apr - Bolivia: Guidance on requests for refunds of export taxes

25 Apr - Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance (Tax Tribunal decision)

25 Apr - Korea: New guidance on improving data collection during customs audits

24 Apr - Australia: Payroll tax payable by mortgage aggregator on commissions paid to brokers (Supreme Court of New South Wales decision)

24 Apr - India: Payment for sharing third-party shrink-wrapped software not a royalty (tribunal decision)

24 Apr - UK: Related-party interest arm’s length but still disallowed based on unallowable purpose (Court of Appeal decision)

24 Apr - UK: Taxpayer’s arguments that no withholding tax due on interest paid to foreign lenders rejected (Court of Appeal decision)

24 Apr - United States: IRS Independent Office of Appeals announces formation of alternative dispute resolution program management office

23 Apr - Germany: VAT treatment of vouchers (CJEU judgment)

23 Apr - Poland: Public country-by-country reporting implemented

23 Apr - Poland: Timing of tax exemption; inheritance and donation tax exemption; insurance proceeds not exempt income (Supreme Administrative Court decisions)

23 Apr - Australia: Update on “Next 5,000” private groups tax performance program

22 Apr - Austria: Draft law implementing public country-by-country reporting

22 Apr - Bolivia: Extended deadline for filing corporate income tax forms, statements

22 Apr - United States: Georgia (income tax rate changes); Illinois (retailer’s occupation tax); New Jersey (sourcing for corporation business tax)

19 Apr - Czech Republic: Taking into account estimated payables for income tax purposes (Supreme Administrative Court decisions)

19 Apr - Germany: New transfer pricing regulations for intra-group financial transactions

19 Apr - Serbia: Protocol to Switzerland income tax treaty adopted by Parliament

19 Apr - Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules

18 Apr - Australia: Extension of due date for certain tax returns due 15 May to 5 June

18 Apr - Australia: Performance audit report on management of transfer pricing for related-party debt

18 Apr - United States: Foreign insurance companies; effectively connected net investment income (2023)

18 Apr - Germany: “Planned cooperation” between charitable corporations (fiscal court decision)

17 Apr - India: Update on tax treaty with Mauritius

16 Apr - United States: IRS Commissioner Werfel testifies at Senate Finance Committee hearing on 2025 IRS budget and IRS’s 2024 filing season

16 Apr - United States: Relief with respect to certain required minimum distributions

16 Apr - Australia: Changes to trust tax returns and private rulings application forms

16 Apr - Poland: Excise tax warehouse as place of import, charitable spending requirement, no gain upon transfer of real estate title as security (court decisions)

16 Apr - Poland: Reporting obligations for digital platform operators (DAC7) enacted, other tax-related legislative developments

16 Apr - Poland: VAT account not accessible asset in bankruptcy proceedings (CJEU Advocate General opinion)

15 Apr - India: Discrimination in extending time limit for registration by new charitable institutions held unconstitutional (High Court decision)

15 Apr - United States: Florida (sales tax rate on use of real property); Pennsylvania (sales tax on SaaS); New York (challenge to P.L. 86-272 regulations)

15 Apr - United States: Limited relief from underpayment of estimated tax attributable to CAMT liability

15 Apr - United States: Partnership audit rules and specific IRS forms

12 Apr - United States: IRS corrects appendices to Notice 2024-20, census tracts for credit under section 30C

11 Apr - Canada: Reminder of 30 April 2024 deadline for tax on cross-border insurance

11 Apr - Czech Republic: Deductibility of increased interest; uncollectible debt (Supreme Administrative Court decisions)

11 Apr - Italy: Scope of self-disclosure regime extended to certain VAT-registered companies and deadline extended to 31 May 2024

11 Apr - Panama: Updated list of reportable jurisdictions under CRS regime

11 Apr - UK: EC erred in finding illegal State aid based on controlled foreign company rules in isolation (CJEU Advocate General opinion)

10 Apr - UK: Labour announces plans to close tax gap

10 Apr - Cyprus: FAQs on adoption of new transfer pricing legislation

10 Apr - Uruguay: Production environment required for submission of CRS reports is available until 30 June 2024

9 Apr - Germany: FATCA reporting deadline is 31 July 2024

8 Apr - Bahrain: Deadline for country-by-country reporting filings for FY 2023 is 31 December 2024

8 Apr - KPMG report: Global e-invoicing and digital reporting mandates

8 Apr - KPMG report: Transfer pricing and ESG—improving governance by operationalizing transfer pricing

8 Apr - Luxembourg: Referral to CJEU for failing to correctly transpose ATAD interest limitation rules

8 Apr - Poland: No taxable income upon lapse of statute of limitations, treatment of Norwegian VAT, appropriate individual tax form (court decisions)

8 Apr - Poland: Public country-by-country reporting bill approved by lower house of Parliament, updated national list of non-cooperative jurisdictions

8 Apr - Sweden: Withholding tax on foreign public pension funds incompatible with EU law (CJEU Advocate General opinion)

8 Apr - United States: Arizona (sales tax nexus); Kentucky (unitary combined reporting); Minnesota (corporate NOL limit change)

5 Apr - United States: Comments on expanding tax certainty and issue resolution programs for business taxpayers

5 Apr - Cyprus: Extension of deadline for submission of data to register of beneficial owners for certain “refugee” companies

5 Apr - Hungary: Audit plan for 2024 focuses on transfer pricing

4 Apr - United States: IRS provides tax relief for taxpayers in Maine and Rhode Island affected by severe storms, flooding

4 Apr - Australia: Law requiring public disclosure of tax residency passes Parliament

3 Apr - Poland: Employee compensation under settlement; cashless payments; VAT on payment for transmission easement (court decisions)

3 Apr - Poland: New bill implementing reporting obligations for digital platform operators (DAC7)

2 Apr - United States: Taxpayers automatically entitled to extension to file petition by reason of COVID-19 disaster declaration (U.S. Tax Court)

2 Apr - KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations

2 Apr - Saudi Arabia: E-invoicing requirement extended to 10th group of taxpayers from 1 October 2024

1 Apr - Bahrain: New FATCA / CRS directive

1 Apr - India: Taxpayer not providing intermediary services for service tax purposes (Supreme Court decision)

1 Apr - United States: Arkansas (sales tax on temporarily used vehicles); Idaho (unclaimed property law changes); multistate (tax rate changes)

March 2024

29 Mar - United States: APMA program, APA statistics for 2023

29 Mar - Canada: Relief for bare trusts from new information reporting requirements

29 Mar - KPMG report: New UK transfer pricing guidance on allocation of risk in controlled transactions

29 Mar - Netherlands: Public country-by-country reporting implemented

28 Mar - China: WTO dispute regarding U.S. tax credits for electric vehicles, renewable energy

28 Mar - South Africa: Comparable uncontrolled price method held most reliable method (court decision)

28 Mar - South Africa: FATCA and CRS third party data submission period

28 Mar - United States: Conservation easement contribution regulations held invalid under APA because of failure to respond to significant comment (U.S. Tax Court)

28 Mar - United States: Disclosure of specified return information to Bureau of the Census for statistical purposes

27 Mar - United States: IRS extends tax relief for taxpayers affected by wildfires in Hawaii

27 Mar - Estonia: Penalties on taxpayer who failed to appear in person to provide explanations to tax authority upheld (District Court judgment)

27 Mar - Netherlands: Interest deduction denied under fraud provision of corporate income tax law (Supreme Court decision)

26 Mar - Poland: Cash register receipts alone are valid evidence of overstated VAT (CJEU judgment)

26 Mar - United States: IRS announces tax relief for taxpayers in Alaska affected by severe storms

25 Mar - Australia: Taxpayer entitled to interest deductions with respect to foreign related-party financing for third-party acquisition (Federal Court decision)

25 Mar - United States: Guidance for qualified student loan and qualified mortgage bonds

25 Mar - United States: Louisiana (exempt cable services); Wisconsin (property tax exemption)

22 Mar - United States: Expanded rules for energy community production and investment tax credits under “Inflation Reduction Act"

22 Mar - United States: Taxpayer’s petition cannot be dismissed by Tax Court on grounds of mootness (Third Circuit)

22 Mar - United States: Certain charitable remainder annuity trust transactions identified as listed transactions

22 Mar - United States: IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals

21 Mar - Finland: Legislation implementing Pillar Two global minimum tax

21 Mar - Finland: Updated FATCA and CRS technical guidance

21 Mar - United States: Taxpayer notification in advance of IRS contact with third parties

20 Mar - United States: Housing expense limit adjustments, foreign locations for 2024

20 Mar - United States: Second quarter update to IRS 2023-2024 Priority Guidance Plan

20 Mar - Anguilla: FATCA and CRS reporting deadline remains 31 May 2024

20 Mar - Greece: Extension of deadlines for updating retail payment systems

20 Mar - Netherlands: Interest deduction limitation rule compatible with EU law (CJEU Advocate General opinion)

19 Mar - Bahamas: Updated FATCA and CRS reporting deadlines

19 Mar - Germany: Guidance on shareholder data reporting requirement for listed companies beginning 2025

19 Mar - Germany: Updated CRS communication manual

19 Mar - KPMG report: Amount B compliance challenges

19 Mar - KPMG report: Implications of ICAP statistics

19 Mar - Luxembourg: Tax authorities begin FATCA and CRS audits

19 Mar - Poland: Interpretation of retail sales tax law; lump-sum car allowance taxable; expenses for B2B team-building meetings not deductible (Supreme Administrative Court decisions)

19 Mar - Sweden: Taxpayer entitled to penalty relief for incorrectly claimed interest deductions (Court of Appeal decision)

19 Mar - United States: Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions

18 Mar - United States: Montana (water’s-edge election); Oregon (guidance for “foreign” corporations); Tennessee (franchise tax refunds); multistate (short-term rental obligations)

18 Mar - Netherlands: Old taxpayer portal used for filing VAT returns will close 1 July 2024

18 Mar - Netherlands: Pension funds not treated as special investment funds eligible for VAT exemption (CJEU Advocate General opinion)

15 Mar - Australia: Draft legislative instruments on filing requirements for 2024 returns

15 Mar - Australia: General anti-avoidance rule did not apply to taxpayer’s distribution of income (Full Federal Court decision)

15 Mar - Cyprus: Compliance campaign for stamp tax liability

15 Mar - EU: Taxpayer appeals General’s Court dismissal of challenge to EU minimum tax directive

15 Mar - India: Service permanent establishment; provision of cloud-based software-driven platform as technical services (court decisions)

14 Mar - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget

14 Mar - United States: IRS adds FAQ to QI / WP / WT FAQs website

14 Mar - United States: New beneficial ownership information reporting requirements

13 Mar - United States: Final regulations on direct pay of certain tax credits under IRA, observations and analysis

13 Mar - Kenya: New platform for non-VAT registered taxpayers to electronically generate and send invoices

12 Mar - Australia: Taxpayer failed to meet burden of proof in transfer pricing dispute (Full Federal Court decision)

12 Mar - Liechtenstein: Updated AEOI correction and deletion procedures

12 Mar - Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition

12 Mar - Poland: General working time not eligible for R&D relief (Supreme Administrative Court decision)

11 Mar - United States: Colorado (manufacturing exemption); New Mexico (individual and corporate income tax changes); New York (taxable information services)

11 Mar - United States: Treasury releases “Green Book” explanation of tax proposals in FY 2025 budget

11 Mar - Czech Republic: Beneficial ownership of royalties; VAT exemption for intra-community supply; proof of “essential costs” (Supreme Administrative Court decisions)

11 Mar - EU: VAT obligations of digital platforms pre-2015 (CJEU referral)

11 Mar - Italy: Transfer pricing requirements for investment manager exemption

8 Mar - Cyprus: Submission of statements of dividend and interest withholding forms expected soon

8 Mar - United States: Guidance on refund claims for invalidated Pinal County tax (Arizona)

7 Mar - United States: Request for recommendations for IRS 2024-2025 Priority Guidance Plan

7 Mar - United States: IRS to waive dyed diesel fuel penalty in parts of Texas; wildfire-related relief

7 Mar - Serbia: VAT refund for 2023 to foreign taxpayers

7 Mar - Sweden: Further guidance on application of “3:12 rules” in cases of significant outside ownership (Tax Court Board decision)

6 Mar - Bolivia: Deadline for filing and payment of financial transaction tax extended to 8 March 2024

6 Mar - Channel Islands: FATCA and CRS deadlines and reporting requirements (Guernsey)

6 Mar - India: Centralization of FATCA and CRS self-certifications

6 Mar - Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting

6 Mar - Saint Kitts and Nevis: Updated AEOI compliance form guidelines

5 Mar - Australia: Overhead costs apportioned to GST-free supplies entitled to input tax credits (Full Federal Court decision)

5 Mar - Czech Republic: No exemption under EU VAT common system when proof not provided that recipient is taxable person (CJEU judgment)

5 Mar - EU: European public prosecutor's office estimates serious VAT fraud amounting to €11.5 billion

5 Mar - India: Deductions for payments to nonresidents upheld; discount by telecom company to distributor not a commission (court decisions)

5 Mar - Spain: Digital platform operators must file returns under DAC7 by 8 April 2024

4 Mar - United States: California (dividends fully included in sales factor); Minnesota (retail delivery fee); Oklahoma (food sales tax); South Carolina (combined reporting)

4 Mar - United States: Taxpayer options for fixing federal tax return mistakes

4 Mar - Bahrain: Extension of record retention period for VAT

4 Mar - Belgium: Mandatory disclosure rules (DAC6) compatible with EU law (CJEU Advocate General opinion)

4 Mar - Cambodia: Market interest rate for related party loans; incentives for voluntary amendment of tax declarations

4 Mar - Malta: Updated automatic exchange of information (AEOI) implementing guidelines

1 Mar - Azerbaijan: Electronic accounting required for certain entities

1 Mar - Cyprus: Guidance on submission of data to register of beneficial owners

February 2024

29 Feb - United States: IRS announces new effort focused on high-income non-filers

29 Feb - United States: IRS LB&I division adds new compliance campaign (business aircraft)

29 Feb - United States: Senate confirms Marjorie Rollinson to be IRS Chief Counsel

29 Feb - Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended

29 Feb - Nigeria: NMDPRA’s right to impose and collect certain levies upheld (Federal High Court decision)

28 Feb - United States: IRS provides tax relief for taxpayers in Washington State affected by wildfires

28 Feb - Belgium: Application of anti-abuse provision upheld even though taxpayer not involved in all parts of transaction (Supreme Court decision)

28 Feb - Hungary: Updated CRS filing instructions

28 Feb - India: Guidance on waiver of certain outstanding direct tax liabilities

28 Feb - Romania: FATCA and CRS reporting deadline is 15 May 2024

28 Feb - Serbia: Individual income tax filing deadlines and rates for 2023

28 Feb - UAE: Timelines for corporate tax registration

27 Feb - Korea: Software fees paid to Irish affiliate treated as royalties paid to U.S. parent (Tax Tribunal decision)

27 Feb - United States: Administrative exemption from requirement to electronically file Form 1042

27 Feb - United States: IRS provides tax relief for taxpayers in California affected by severe storms, flooding

26 Feb - United States: Alaska (marketplace facilitators sales tax); Louisiana (industrial tax exemption program); New York (wine producer as qualified manufacturer); Wisconsin (withholding on software licensing income)

26 Feb - Hungary: Updated FATCA filing instructions

26 Feb - Poland: Payments to employees on leave qualify as eligible R&D expenses

26 Feb - Poland: Social security liability; reduction in depreciation rates for prior years; taxable base for real estate taxes (court decisions)

26 Feb - UK: Closure notice held valid (First-tier Tribunal decision)

26 Feb - United States: BIS revises EAR entity list

26 Feb - United States: Notice of filing of petition for addition of iso-butanol to Superfund list

23 Feb - United States: OFAC issues Russia-related general licenses, FAQs, and designations

23 Feb - United States: Comment period reopened for proposed regulations under section 6050S (qualified tuition expenses), section 25A (education tax credits)

23 Feb - Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament

22 Feb - Australia: First list of companies receiving failure to comply notices under payment times reporting law

22 Feb - New Zealand: No adoption of Amount B

22 Feb - United States: BIS revises license requirements and export controls for certain camera technologies

22 Feb - United States: IRS announces plans to begin audits on personal use of business aircraft

22 Feb - United States: IRS TE/GE division provides new technical guide

21 Feb - Australia: Ruling on technology-based platform to ascertain fuel use for purposes of fuel tax credit

21 Feb - Australia: “Top hatting” transaction did not qualify for basis step up (Federal Court decision)

21 Feb - Ethiopia: New transfer pricing rules

21 Feb - Kenya: Transfer pricing developments

21 Feb - Kenya: Stay of new affordable housing levy upheld (Court of Appeal decision)

21 Feb - KPMG report: Overview and initial observations on Pillar One – Amount B

21 Feb - KPMG report: HMRC guidance on OECD’s control of risk framework

21 Feb - United States: Filing of petitions for additions of caprolactam and nylon 6 to Superfund list

21 Feb - United States: Allocation and apportionment of R&E expenses for tax years beginning before 1 January 2020

21 Feb - United States: Interest rates, tax underpayments and overpayments remain same for second quarter 2024

21 Feb - United States: Decision in favor of IRS in case regarding limited partner exception to self-employment income (U.S. Tax Court)

21 Feb - United States: Financing costs, including bond fees, properly included in eligible basis for purposes of low-income housing tax credit (U.S. Tax Court)

20 Feb - United States: Treasury launches website tracking tax guidance under “Inflation Reduction Act”

20 Feb - United States: New Jersey (substantiation of sales tax refund claims); Washington State (B&O tax on reimbursements); Wisconsin (pre-combined reporting NOLs)

20 Feb - India: Computer airline reservation system located in U.S. did not create permanent establishment in India (tribunal decision)

20 Feb - Nigeria: Migration of electronic platform for filing transfer pricing returns and country-by-country notifications

20 Feb - Poland: Corporate income tax on buildings; tax-deductible costs; revenue from trademark (Supreme Administrative Court decisions)

20 Feb - Poland: Draft legislation implementing new reporting obligations for digital platform operators (DAC7)

20 Feb - Poland: Guidance and consultation on national e-invoicing system (KSeF)

16 Feb - France: Tax authority guidance on VAT treatment of non-fungible tokens

16 Feb - India: Constitutionality of anti-profiteering provisions under GST upheld (High Court decision)

16 Feb - India: Sales proceeds in escrow account not includable in capital gains (tribunal decision)

16 Feb - United States: Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)

16 Feb - United States: Liability of third-party payers for improperly claimed employee retention credits

15 Feb - United States: California court decision on interstate tax law

15 Feb - United States: IRS provides tax relief for taxpayers in Michigan affected by severe storms, tornadoes and flooding

15 Feb - United States: Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

15 Feb - Netherlands: Qualification of land as developed or undeveloped for VAT purposes (Supreme Court decision)

15 Feb - Spain: Guidance under new mandatory corrective self-assessment procedure for direct and indirect taxes

14 Feb - Czech Republic: Deadline for assessing tax; technical improvement of real property (Supreme Administrative Court decisions)

13 Feb - Channel Islands: Updated FATCA and CRS practical guidance; common errors in reporting (Jersey)

13 Feb - Greece: Guidance on new reporting obligations for digital platform operators (DAC7)

13 Feb - Poland: VAT rate on take-away meals; eligible costs of new investment projects (Supreme Administrative Court decisions)

13 Feb - United States: Application period for environmental justice solar and wind capacity limitation program closing 29 February

12 Feb - United States: Delaware (unclaimed property voluntary disclosure agreement program); Illinois (tax treatment when mobile app used to purchase fuel); South Dakota (use tax on equipment)

12 Feb - United States: Effective dates for changes to user fee schedule for determination letters

12 Feb - United States: Indexing adjustments for amounts used to calculate employer shared responsibility payments

12 Feb - Australia: Guidance on LIFO method for securities holding period requirement

12 Feb - Australia: Revised draft legislation implementing public country-by-country reporting

12 Feb - EU: VAT treatment of transfer pricing adjustments (CJEU referral from Romania)

12 Feb - UK: Income tax treaty relief for foreign dividends (Upper Tribunal decision)

12 Feb - UK: Taxpayer not estopped from arguing invalidity of inquiry notices (First-tier Tribunal decision)

12 Feb - UK: Time limits for discovery assessments relating to stamp duty land tax (First-tier Tribunal decision)

9 Feb - Belgium: Provisions transposing DAC6 mandatory disclosure rules annulled (Constitutional Court decisions)

9 Feb - Belgium: Public country-by-country reporting implemented

9 Feb - EU: Certain member states extend DAC7 reporting deadlines

9 Feb - Netherlands: FAQs on reporting obligations of digital platform operators (DAC7)

8 Feb - Hong Kong: Comprehensive double taxation agreement with Croatia signed

8 Feb - KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups

8 Feb - KPMG report: Legal advice memorandum shows IRS approach to intercompany debt pricing

8 Feb - Singapore: Reminder that deadline for CRS registration is 31 March 2024

8 Feb - Sweden: Guidance on application of “3:12 rules” in cases of significant outside ownership (Supreme Administrative Court decision)

7 Feb - Netherlands: EC approval of COVID-19 related State aid annulled (CJEU General Court judgment)

7 Feb - United States: IRS provides tax relief for taxpayers in West Virginia affected by severe storms, flooding, landslides, and mudslides

7 Feb - United States: Temporary extension of time to submit seller reports for transfers of clean vehicle credits

6 Feb - United States: IRS provides revised FAQs on Form 1099-K

6 Feb - Malta: Transfer pricing guidelines

6 Feb - Pakistan: Guidance regarding electronic transmission of sales tax invoices

6 Feb - Poland: Board member liability for VAT arrears (CJEU referral)

6 Feb - Poland: Taxpayers may retroactively change depreciation rates (Supreme Administrative Court decision)

5 Feb - United States: IRS provides tax relief for taxpayers in Maine affected by severe storms, flooding

5 Feb - United States: Missouri (REIT dividends deductible); New York (qualified emerging technology company); multistate (worldwide combined reporting)

5 Feb - United States: Navigating the shifting landscape of research credit audits

5 Feb - Belgium: Parliament approves new law project to introduce e-invoicing mandate from 1 January 2026

5 Feb - Canada: Consultation on R&E program, patent box regime

5 Feb - Nigeria: Deadline for filing employer annual tax returns extended to 15 February 2024 (Anambra State)

2 Feb - Australia: Proposed retroactive adoption of updated OECD transfer pricing guidance

2 Feb - Indonesia: New regulations for transfer pricing documentation, MAPs, APAs

2 Feb - KPMG report: Mexican rulings on exportation of services eligible for 0% VAT

2 Feb - Malta: Time limitation on applicability of grandfathering provision under transfer pricing rules

1 Feb - Cambodia: Approved treaty benefits effective for full calendar year

1 Feb - Cambodia: Real estate taxes relief, procedures for online amendment of monthly tax declarations

1 Feb - Colombia: Modified tax Form 490 includes significant economic presence corporate income tax payments

1 Feb - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (February 2024)

1 Feb - Nigeria: Deadline for filing employer annual tax returns extended to 7 February 2024 (Lagos State)

January 2024

31 Jan - United States: House passes bipartisan tax extenders legislation

31 Jan - United States: New year, changing information reporting and withholding (IRW) requirements

31 Jan - Finland: FATCA and CRS annual information returns due 31 January 2024

30 Jan - EU: Public country-by-country reporting implementation summary

30 Jan - Australia: Guide on details of R&D tax transparency reports

30 Jan - EU: Penalty relief due to technical issues related to CBAM registry and import control system 2

30 Jan - India: Capital loss arising from cancellation of shares is allowable to shareholders even if no consideration is paid (tribunal decision)

30 Jan - Poland: Employer not liable for VAT based on fraudulent invoices prepared by employee (CJEU judgment)

30 Jan - Poland: Procedure for filing transfer pricing reporting forms for acquired entities

30 Jan - Poland: Sublicense receivables treated as capital assets; taxation of refunds from employee capital plans (Supreme Administrative Court decisions)

30 Jan - OECD: Aggregated ICAP statistics

30 Jan - UK: Updated transfer pricing guidance on allocation of risk in controlled transactions

29 Jan - UK: Capital Allowances on camping pods (First-tier Tribunal decision)

29 Jan - UK: Government response to consultations on proposed changes to transfer pricing and international tax rules

29 Jan - UK: Unallowable purpose, connection, and control (First-tier Tribunal decision)

29 Jan - United States: Colorado (sales and use tax); New York (property tax exclusion); multistate (online marketplace sales)

29 Jan - United States: Practical tax mechanics of implementing SEC clawbacks

26 Jan - United States: Avoiding common pitfalls in oil and gas reserve valuations for U.S. tax purposes

26 Jan - United States: IRS provides tax relief for taxpayers in Rhode Island affected by severe storms, flooding, and tornadoes

26 Jan - United States: IRS TE/GE division releases summary of “FY 2023 accomplishments”

26 Jan - Philippines: Reduction in accounts receivable did not result in VAT deficiency (Court of Tax Appeals decision)

25 Jan - Colombia: New deadlines for transfer pricing documentation

25 Jan - United States: Proposed legislation authorizing franchise tax refunds (Tennessee)

25 Jan - United States: Special relief for certain rollovers to or from Maryland prepaid college trust accounts

24 Jan - Albania: Withholding tax and double tax treaties applications

24 Jan - Bolivia: Extended deadline for filing, payment, and compliance with RC-VAT tax obligations for direct taxpayers

24 Jan - Netherlands: Only beneficial owner of dividend entitled to credit dividend withholding tax (Supreme Court decision)

24 Jan - South Africa: Interest incurred by investment holding company held nondeductible (High Court decision)

24 Jan - Spain: Several corporate tax law measures declared unconstitutional (Constitutional Court decision)

23 Jan - Poland: Taxation of employee incentive shares; supplementary capital contribution deductible (Supreme Administrative Court decisions)

23 Jan - Sweden: Interest deductions incurred to finance intra-group share acquisition allowed (Supreme Administrative Court decision)

22 Jan - Korea: Sales support services subject to zero rate of VAT (Tax Tribunal decision)

22 Jan - South Africa: Vendors must respond to VAT verification requests with 40 business days

22 Jan - United States: Comment period reopened for proposed regulations on federal independent dispute resolution (IDR) process

22 Jan - United States: Florida (sales factor litigation); Massachusetts (corporate excise tax changes); Washington State (capital gains as excise tax case)

22 Jan - United States: IRS provides tax relief for taxpayers in Connecticut affected by severe storms

22 Jan - United States: Resurgence of transfer pricing penalties

19 Jan - United States: Guidance on qualified alternative fuel vehicle refueling property credit under section 30C

19 Jan - Belgium: Anti-abuse rule applied to deny withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision)

19 Jan - Bulgaria: Public country-by-country reporting implemented

19 Jan - Czech Republic: Public country-by-country reporting implemented

19 Jan - EU: Challenge to EU global minimum tax directive dismissed (EU General Court judgment)

19 Jan - Italy: Procedure for obtaining hybrid mismatch penalty protection

19 Jan - Poland: Mandatory e-invoicing system postponed

19 Jan - Portugal: “Windfall profits tax” on banks incompatible with EU law (CJEU judgment)

18 Jan - United States: Updated accounting method change procedures and clarification of rules addressing capitalization of research and experimentation costs under section 174

18 Jan - United States: IRS announces certain tax-exempt organizations cannot e-file Form 990-T or Form 1120-POL until 17 March

17 Jan - Czech Republic: Treaty must be interpreted based primarily on general interpretation rules (Supreme Administrative Court decision)

17 Jan - Italy: New tax calendar, implications for transfer pricing documentation

17 Jan - United States: Key takeaways from recent CAMT releases

16 Jan - India: Reassessment proceedings inapplicable to capital account transaction (High Court decision)

16 Jan - Japan: Updated CRS FAQs on AEOI reporting system

16 Jan - Poland: Taxation of benefits provided to workers in another EU member state; deductibility of debt financing costs (Supreme Administrative Court decisions)

16 Jan - UK: Updates on Pillar Two, including draft HMRC guidance on proposed rules

16 Jan - United States: Connecticut (solar electricity property tax exemption); Pennsylvania (sourcing); Michigan (income tax nexus)

16 Jan - United States: Transitional guidance on reporting of information on receipt of digital assets

12 Jan - United States: Initial guidance on pension-lined emergency savings accounts

12 Jan - United States: Updated guidance on availability of administrative exemptions from requirement to file electronically

12 Jan - Belgium: Law project to introduce a new e-invoicing mandate from January 2026

12 Jan - Mexico: Updates to presentation of 2023 annual declaration of legal entities

12 Jan - Romania: New reporting requirements for international shipment of goods

12 Jan - United States: IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships

12 Jan - United States: Updated beneficial ownership information reporting FAQs

11 Jan - Bolivia: Deadline to implement online billing modalities for eighth, ninth, and tenth groups of taxpayers

11 Jan - Canada: Updated list of imported goods targeted for potential audits

11 Jan - KPMG report: Comments on European Commission consultation on transfer pricing initiative

11 Jan - United States: Additional time and penalty relief for partnerships to provide complete Forms 8308 for 2023 section 751(a) exchanges

11 Jan - United States: IRS announces changes to QI / WP / WT FAQs website

10 Jan - United States: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

10 Jan - United States: National Taxpayer Advocate report to Congress identifying taxpayer problems

9 Jan - Bolivia: Certain taxpayers to implement online billing modality

9 Jan - Serbia: Amendments to rulebook on e-invoicing adopted

8 Jan - United States: Extension of comment period for proposed regulations on excise taxes on taxable distributions from donor advised funds

8 Jan - United States: Florida (sales and use tax); New York (corporate franchise tax reforms); multistate (P.L. 86-272)

8 Jan - Cyprus: Registration in tax registry must be done electronically through taxpayer portal

8 Jan - Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates

8 Jan - Poland: Refusal to apply preferential withholding tax treatment upheld; R&D conducted by contractor treated as carried out by taxpayer (Supreme Administrative Court decisions)

5 Jan - India: Guidelines for withholding tax on e-commerce transactions

5 Jan - Saudi Arabia: Guidance on resident natural persons subject to income tax

5 Jan - United States: Proposed regulations on clean hydrogen production credit and related energy credit (KPMG report)

5 Jan - United States: IRS announces more time for dealers and sellers of clean vehicles to submit time-of-sale reports

4 Jan - Netherlands: Farewell bonuses not treated as non-deductible participation selling costs (Supreme Court decision)

4 Jan - Qatar: Extended deadline for country-by-country reports and notifications

4 Jan - Senegal: Commitment to start automatic exchange of information (AEOI) by 2025

4 Jan - Sweden: Revaluation of tax base for VAT purposes for group-wide services (CJEU referral)

3 Jan - North Macedonia: New rulebook on VAT registration of foreign taxpayers through a tax representative

3 Jan - Serbia: Amendments to VAT rulebook

3 Jan - United States: Butane not eligible for alternative fuel mixture tax credit (Federal Circuit)

2 Jan - KPMG report: Pillar Two rules and the asset management industry

2 Jan - Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax

2 Jan - United States: IRS annual revenue procedures for 2024

2023 Articles

December 2023

29 Dec - United States: Request for comments on product identification number requirement for energy efficiency home improvement

29 Dec - United States: Termination of United States-Hungary tax treaty effective 1 January 2024

28 Dec - United States: Guidance on the application of section 961 to certain inbound nonrecognition transactions

28 Dec - United States: Transitional procedures for applicable entities to claim statutory exceptions to phaseouts for clean energy credits if domestic content requirements not met

28 Dec - United States: Updated list of treaties meeting qualified dividend requirements adds Chile, removes Hungary and Russia

27 Dec - Bermuda: Legislation introducing corporate income tax signed into law

26 Dec - Bolivia: Extended deadline to present affidavits and pay taxes for certain oil companies

26 Dec - China: Advance pricing arrangement annual report for 2022

26 Dec - Luxembourg: Director’s fees not subject to VAT (CJEU judgment)

26 Dec - United States: IRS extends QI/WP/WT certification due date

26 Dec - United States: IRS updates FAQs on clean vehicle credits

22 Dec - United States: IRS announces tool for elective payment or transfer of credits under IRA and CHIPS

22 Dec - United States: Modified guidance on application of section 174

22 Dec - Cambodia: Effective date of notification letters or other notices from tax authority

22 Dec - Cyprus: VAT return deadline extension

22 Dec - EU: EC publishes FAQs on interpretation and transposition of EU global minimum tax

22 Dec - Korea: Substance over form principles applied to disregard intermediate third-party suppliers (Administrative Court decision)

22 Dec - United States: Foreign tax credits for multinationals

22 Dec - United States: IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms

22 Dec - United States: New voluntary disclosure program for employee retention credit

22 Dec - United States: Proposed regulations on advanced manufacturing production credit under section 45X

21 Dec - Australia: ATO definition of “contractors” vs. “employees”

21 Dec - Chile: U.S. income tax treaty enters into force

21 Dec - Korea: Taxation of fees under trademark license (Supreme Court decision)

21 Dec - Netherlands: Waiver of default penalties for non-compliance with OSS mechanisms of VAT e-commerce package

21 Dec - Philippines: Tax audits suspended until 7 January 2024

21 Dec - Poland: Suspension of statute of limitations constitutional; maximum tax rate for residential buildings; deduction of input VAT on employee accommodations (court decisions)

21 Dec - United States: JCT releases “Bluebook” on tax legislation in 117th Congress

20 Dec - United States: 2023 cumulative list of changes in plan qualification requirements for defined contribution qualified pre-approved plans

20 Dec - United States: Enforcement of price cap on Russian oil, updated guidance

20 Dec - United States: Extended deadline is 15 April 2025, for individuals with signature authority

20 Dec - United States: Guidance on certain provisions of Secure Act 2.0

20 Dec - United States: Preparing for the new excise tax under section 5000D on sales of specified drugs

20 Dec - United States: Relief from additions to tax for failure to pay with respect to certain 2020 and 2021 income tax returns

20 Dec - United States: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

20 Dec - Belgium: Compatibility of “fairness tax” with EU law (CJEU referral)

20 Dec - Chile: Guidance on obligation of digital service platforms to issue third-party electronic invoices; other direct and indirect tax developments

20 Dec - Cyprus: Submission of data on ultimate beneficial owners due 29 February 2024

20 Dec - Czech Republic: Law incorporating corporate sustainability reporting directive (CSRD) enacted

20 Dec - France: Claims for foreign tax credits on dividends rejected (court decision)

20 Dec - KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis

20 Dec - Luxembourg: Law implementing Pillar Two global minimum tax enacted

20 Dec - Netherlands: Senate approves legislation implementing public country-by-country reporting

20 Dec - Spain: Notifications for excise taxes required during first few months of 2024

19 Dec - Australia: Taxpayer alerts regarding artificial inflation of R&D tax incentive claims

19 Dec - Azerbaijan: VAT on cross-border provision of digital services

19 Dec - Barbados: CRS guidance on entities self-certifying as financial institutions

19 Dec - Estonia: Board member liable for taxes; Finnish tax liability collectible (Circuit Court decisions)

19 Dec - EU: Suspension of rebalancing tariffs on U.S. products extended to 31 March 2025

19 Dec - Spain: Requirements for billing systems as of 1 July 2025

19 Dec - United States: Accounting standards update includes improvements to income tax disclosures

19 Dec - United States: Income tax treaty with Chile enters into force

18 Dec - United States: De minimis error safe harbor exceptions to penalties for failure to file correct information returns or furnish correct payee statements

18 Dec - United States: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

18 Dec - United States: IRS enforcement on high-income and high-wealth individuals

18 Dec - United States: Updated list of jurisdictions for exchanging deposit interest information

18 Dec - India: Fees received for domain name registration services not taxable as royalty (High Court decision)

18 Dec - OECD: Further administrative guidance on Pillar Two rules; statement on timeline of Pillar One multilateral convention

18 Dec - Saudi Arabia: Zakat treatment of related-party transactions; thresholds for transfer pricing documentation for Zakat payers

15 Dec - Belgium: Pillar Two global minimum tax rules adopted by Parliament

15 Dec - KPMG report: Transfer pricing implications of Pillar Two minimum tax rules

15 Dec - Agreement between European Council and Parliament regarding proposed Corporate Sustainability Due Diligence Directive

15 Dec - United States: Additional interim guidance on new corporate alternative minimum tax (CAMT)

15 Dec - United States: Additional guidance on new sustainable aviation fuel credits

14 Dec - Australia: New tax treaty negotiation program with Ukraine and Brazil

14 Dec - Barbados: AEOI portal open for prior year submissions until 15 December 2023

14 Dec - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU judgment)

14 Dec - Moldova: Public country-by-country reporting implemented

14 Dec - Poland: Surcharge on alcoholic beverages applicable; loan management services not VAT-exempt (Supreme Administrative Court decisions)

14 Dec - Sweden: Corrections related to new information from Pandora leak due by 29 February 2024 to avoid penalties

13 Dec - United States: IRS announces plans for new leadership structure

13 Dec - Czech Republic: VAT deduction on anti-radar equipment; VAT treatment of transfer of technical improvements at lease end (Supreme Administrative Court decisions)

13 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5

12 Dec - Canada: Information reporting requirements for trusts

12 Dec - Belgium: Requirements for mixed VAT taxpayers calculating VAT deductions using general pro rata method

12 Dec - Canada: GST/HST obligations of employer-sponsored pension plans, 31 December deadline

12 Dec - Hong Kong: Upfront lump sum and annual royalties received from UK company taxable in Hong Kong (Court of First Instance decision)

12 Dec - United States: Updated beneficial ownership information reporting FAQs

11 Dec - United States: Guidance on application of FTC and DCL rules to Pillar Two taxes, extension and modification of temporary FTC relief

11 Dec - United States: New York (sales tax on party platters); Pennsylvania (Philadelphia voluntary disclosure program); Washington State (B&O and sales tax guidance)

11 Dec - Bahrain: Campaign encouraging VAT registration

11 Dec - Netherlands: Agreement with Belgium on permanent establishment implications of remote working

11 Dec - Philippines: All e-commerce participants subject to Philippine laws, regardless of physical presence

11 Dec - UK: FATCA, CRS guidance on voluntary disclosure of unpaid tax on cryptoassets

8 Dec - Australia: Judgment on embedded royalties and application of diverted profits tax (DPT) publicly released (Federal Court decision)

8 Dec - Belgium: Beneficial ownership concept under Netherlands treaty (Lower Court decision)

8 Dec - Cyprus: Extended “central equal weight sharing tax” payment deadline for real estate and share transfers

8 Dec - Germany: Circumstances of group of companies may be considered in applying new German anti-treaty shopping rule (Lower Court decision)

8 Dec - Hungary: Legislation implementing Pillar Two global minimum tax enacted

8 Dec - Hungary: Local rules applicable to domestic reorganizations inconsistent with EU merger directive (CJEU judgment)

8 Dec - Moldova: Draft law implementing country-by-country reporting

8 Dec - Thailand: Required reporting by digital platform operators

8 Dec - UK: Notice requiring taxpayer to disclose emails containing specified terms upheld (First-Tier Tribunal decision)

7 Dec - Barbados: CRS guidance on reporting of undocumented accounts

7 Dec - Denmark: Deadline for reporting information about employee share plans and share repurchases is 20 January 2024

7 Dec - Italy: Guidance on new reporting obligations for digital platform operators (DAC7)

6 Dec - United States: IRS announces continued increased scrutiny of employee retention credit claims

6 Dec - United States: Transitory relief for Forms 1099-K

6 Dec - Australia: Guidance on tax treatment of off-market share buy-backs

6 Dec - India: No obligation to withhold tax on notional income; income from offshore supply of equipment and services not taxable in India

6 Dec - Luxembourg: Amended draft law implementing Pillar Two global minimum tax

6 Dec - Nigeria: Procedural rule requiring payment of disputed assessments declared unconstitutional

6 Dec - Philippines: Amendments to creditable withholding tax; VAT registration

6 Dec - Poland: Draft regulations related to mandatory use of national e-invoicing system (KSeF)

6 Dec - Poland: R&D activities; individual depreciation rate for certain non-residential premises (Supreme Administrative Court decisions)

5 Dec - KPMG report: OECD official provides update on expected transfer pricing guidance

5 Dec - Belgium: Access to VAT e-services “Isabel” and “GlobalSign” to end beginning 31 January 2024

5 Dec - Bolivia: Modifications to billing system

5 Dec - Luxembourg: European Commission erred in finding grant of State aid (CJEU judgment)

4 Dec - Canada: Tax “fairness relief” requests related to 2013 due by 31 December 2023

4 Dec - Nigeria: Full waiver of penalties and interest on outstanding tax liabilities

4 Dec - United States: Illinois (constitutionality of retailer’s occupation tax); Minnesota (goodwill gain is apportionable business income); Washington State (sales and B&O tax)

1 Dec - United States: Guidance on excluded entity provisions under section 30D clean vehicle credit

1 Dec - KPMG report: IRS large foreign-owned transfer pricing initiative aimed at inbound distributors

1 Dec - Australia: Tax treaty with Portugal signed

1 Dec - Australia: Taxpayer liable for withholding tax on embedded royalties, application of DPT (Federal Court decision)

1 Dec - Spain: Forms for new reporting obligations for digital platform operators (DAC7)

1 Dec - United States: Taxation of beneficiary of a foreign non-grantor trust

1 Dec - United States: Updated guidance on beneficial ownership information reporting requirements

November 2023

30 Nov - Luxembourg: Flat minimum net wealth tax partly declared unconstitutional (Constitutional Court decision)

30 Nov - Pakistan: Overview of ultimate beneficial ownership provisions and reporting framework

30 Nov - Singapore: Updated e-Tax Guide on tax treatment of front-end fees

29 Nov - Barbados: CRS guidance covers reporting of TINs, residence by investment and citizenship by investment schemes

29 Nov - Spain: Constitutionality of temporary solidarity tax on large fortunes upheld, Madrid proposes repeal for its residents

29 Nov - United States: Extended filing deadline for initial beneficial ownership information reports

28 Nov - United States: Court has jurisdiction to determine in partnership-level proceeding application of limited partner exception to self-employment income (U.S. Tax Court)

28 Nov - Australia: CRS reporting for uninhabited jurisdictions and undocumented accounts

28 Nov - Germany: Updated process for reporting of missing self-certifications

28 Nov - Poland: Extended deadline for submitting certain transfer pricing reporting forms

28 Nov - Poland: Taxation of employee share grants; tax depreciation of real estate (court decisions)

28 Nov - Spain: Update on new reporting obligations for digital platform operators (DAC7) 

27 Nov - United States: IRS provides tax relief for taxpayers in Illinois affected by storms

27 Nov - United States: IRS provides tax relief for taxpayers in St. Croix affected by elevated levels of lead and copper in water supply

27 Nov - United States: IRS updates process for requesting information related to tax-exempt organizations

27 Nov - Belgium: Joint VAT liability for electronic interfaces

27 Nov - Greece: Public country-by-country reporting implemented

27 Nov - KPMG report: Transfer pricing of financial transactions

27 Nov - Luxembourg: Temporary VAT rate reductions set to expire 1 January 2024

27 Nov - Philippines: Requirements for refund or credit of input VAT for zero-rated sales and services (Court of Tax Appeals decision)

27 Nov - Saudi Arabia: Ninth wave of e-invoicing applicability

27 Nov - Spain: Compatibility with EU law of application of nonresident income tax on dividend distributions (CJEU referral)

27 Nov - UK: Shares in closely held company treated as employment-related securities for income tax purposes (Supreme Court decision)

27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules

24 Nov - KPMG report: Transfer pricing takeaways from 2022 MAP statistics

21 Nov - Australia: Legislation proposing tax enforcement enhancements

21 Nov - Korea: Beneficial owner of royalties determined by examination of facts and circumstances (Tax Tribunal decision)

21 Nov - Korea: Trends in customs audits

21 Nov - KPMG report: Pillar Two implications for “U.S. sandwich structures”

21 Nov - OECD: Aggregated country-by-country reporting data

21 Nov - Poland: Cash register receipts alone are valid evidence of overstated VAT (CJEU Advocate General opinion)

21 Nov - United States: IRS hearing on digital asset proposed regulations

21 Nov - United States: Rules for qualified pre-approved plans and 403(b) pre-approved plans

21 Nov - United States: Further delay of implementation of $600 reporting threshold for Forms 1099-K; $5000 threshold for 2024 to phase in implementation

20 Nov - United States: California (inclusion of dividends in sales factor); Florida (proposed sales tax holiday); Louisiana (sales tax on online car sharing)

17 Nov - United States: Interest rates, tax underpayments and overpayments remain same for first quarter 2024

17 Nov - Czech Republic: Proposed direct and indirect tax changes, including public country-by-country reporting

17 Nov - United States: Disallowance of deductions for certain conservation easement contributions by partnerships, S corporations

16 Nov - OECD: Public consultation on model treaty commentary on permanent establishments as applied to extractible natural resources

16 Nov - Poland: Extended deadlines for transfer pricing reporting

16 Nov - Poland: Supplies of electricity to foreign partners not subject to VAT; costs deductible against capital gains (court decisions)

16 Nov - United States: Decision upholding IRS determination that fund engaged in U.S. trade or business (U.S. Tax Court)

16 Nov - United States: Notices requesting “verified reports” of unclaimed property (Delaware)

16 Nov - United States: Reply brief for petitioners in Moore case

16 Nov - United States: Updated beneficial ownership information reporting FAQs

15 Nov - United States: Partnership engaged in U.S. trade or business based on activities of asset manager (U.S. Tax Court)

15 Nov - Mexico: Tax relief for taxpayers affected by Hurricane Otis (State of Guerrero)

14 Nov - Finland: Updated FATCA and CRS FAQs

14 Nov - Germany: Law implementing Pillar Two global minimum tax passed by lower house of Parliament

14 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2022

14 Nov - Australia: Changes in not-for-profits reporting requirements

13 Nov - Australia: ATO guidance on Commissioner’s discretion on “control” of a connected entity

13 Nov - Brazil: Guidance on tax on industrialized products (IPI), state sales tax (ICMS)

13 Nov - Brazil: Modification of multiple-year data table under new transfer pricing rules

13 Nov - Czech Republic: Proposed amendments to proving R&D allowances, taxation of employee stock option plans

13 Nov - Italy: New reporting obligations for payment service providers

13 Nov - United States: Adjusting closed-year partnership-related items

13 Nov - United States: Maine (service receipts); Missouri (resale exemption for use tax); Ohio (agent exclusion from CAT base); Texas (increase in franchise tax exemption)

10 Nov - OECD: Countries issue joint statement to commit to cryptoasset reporting framework by 2027

10 Nov - Czech Republic: Pharmaceutical marketing services are separate supply of services not subject to VAT (Supreme Administrative Court decision)

10 Nov - Greece: Guidelines on tax residency of individuals

10 Nov - Serbia: Amendments to electronic invoicing law

10 Nov - UK: Capital allowances for surveys and studies (Upper Tribunal decision)

10 Nov - UK: Share exchange on sale of company not tax avoidance (Court of Appeal decision)

10 Nov - UK: Share options granted by employer deemed part of employee compensation (Supreme Court decision)

9 Nov - Belgium: Referral to CJEU for failing to correctly transpose ATAD CFC rules

9 Nov - EU: List of national portals for reporting to central electronic system of payment information

9 Nov - Greece: Public consultation on implementation of public country-by-country reporting

9 Nov - Ireland: Judgment of General Court regarding tax rulings issued to multinational group must be set aside (CJEU Advocate General opinion)

9 Nov - Ireland: Purchase and resale of second-hand cars does not meet conditions under VAT margin scheme

9 Nov - Sweden: Reservations on proposed EU transfer pricing directive

9 Nov - United States: JCT report on income taxation of high income and high wealth taxpayers, ahead of Senate Finance hearing

9 Nov - Australia: New income tax treaty with Iceland now in force

9 Nov - Australia: Updated practice statement on collection and recovery of disputed tax debts

8 Nov - Australia: Updated practice compliance guideline on simplified transfer pricing record-keeping options, new safe harbor

8 Nov - United States: Brazilian legal restriction not taken into account in determining arm’s length transfer price under section 482 (U.S. Tax Court)

8 Nov - United States: Section 904(f)(3)(A) does not prevent recognition of gain in excess of overall foreign loss account or recharacterize such gain as foreign source income (U.S. Tax Court)

8 Nov - United States: Section 451(b) and specified fees

7 Nov - Poland: Real estate tax on cableways; enforcement fees as public levies; basis of fixed assets for minimum tax purposes (Supreme Administrative Court decisions)

7 Nov - Australia: Updated AEOI guidance provides clarifications on IRS foreign financial institutions list

7 Nov - Germany: No input VAT deductions for import VAT on goods never received (Federal Tax Court decision), other VAT developments

7 Nov - Nigeria: Interest and penalties do not apply to timely contested VAT assessments (Tax Appeal Tribunal decision)

6 Nov - United States: New Jersey (corporation business tax); New York (new employee displacement tax); Texas (data processing services)

6 Nov - United States: New suspicious activity report (SAR) key term for reporting evasion of U.S. export controls

6 Nov - Bulgaria: Recovery of VAT on uncollectible receivables using new electronic service

6 Nov - Canada: List of “notifiable transactions” under new mandatory disclosure rules

6 Nov - Spain: VAT actions required by 30 November 2023 deadline

6 Nov - Switzerland: Blockchain services partially taxable and partially non-taxable for VAT purposes (Federal Administrative Court decision)

3 Nov - Bolivia: Extension of deadline for compliance with tax obligations of the unified agricultural regime

3 Nov - Cyprus: New income tax treaty with Croatia signed

3 Nov - Netherlands: Place of risk and transport exemption for insurance premium tax purposes (court decision)

2 Nov - Canada: CRA extends penalty and interest relief for underused housing tax filing obligations

2 Nov - Canada: Updated export control list, export permit process

2 Nov - Estonia: Income tax assessment based on incorrect valuation of non-monetary contribution to share capital struck down (Supreme Court decision) 

2 Nov - Mexico: Tax relief for taxpayers affected by Hurricane Otis

2 Nov - Nigeria: Updates to online portal, ultimatum on payment of outstanding tax liabilities

2 Nov - Sweden: VAT recovery on the disposal of shares in a subsidiary undertaking (Supreme Administrative Court decision)

2 Nov - United States: Exchange of variable prepaid forward contracts (VPFCs) taxable under section 1234A as short-term capital gain (U.S. Tax Court)

1 Nov - France: VAT digital economy enforcement included in 2024 Finance Bill

October 2023

31 Oct - Luxembourg: Constitutional Court to decide constitutionality of different treatment under minimum net wealth tax for holding companies

31 Oct - Luxembourg: U.S. branch denied permanent establishment status, previous ruling nullified (administrative court decision)

31 Oct - Nigeria: Ancillary income does not constitute inbound freight income (Federal High Court decision)

31 Oct - OECD: Renewed partnership with ATAF to strengthen tax cooperation in Africa

31 Oct - Poland: Deadline for transfer pricing reporting for 2022 extended

31 Oct - Poland: Striking taxable person from VAT register; exit law compatible with EU law; construction management services subject to VAT (court decisions)

31 Oct - UAE: Transfer pricing guide issued

31 Oct - Uganda: Tax authority publishes notice implementing digital services tax

31 Oct - Uruguay: AEOI portal open to CRS report submissions until 30 November 2023

30 Oct - United States: IRS extends acceptance of digital signatures, encrypted emails

30 Oct - United States: IRS adds two FAQs to QI / WP / WT FAQs website

30 Oct - United States: California (Proposition 39 upheld); Kansas (corporate income tax rate reduction); New York (sales tax on clothing); Utah (sales tax on bundled digital subscription fees)

27 Oct - United States: Guidance under No Surprises Act, including federal independent dispute resolution (IDR) process

27 Oct - KPMG report: U.S. transfer pricing and international tax year-end considerations

27 Oct - Nigeria: Rental income from real properties not subject to VAT (Tax Appeal Tribunal decision)

26 Oct - Germany: Loss limitation rule inapplicable because no change in control (lower tax court decision)

26 Oct - Saudi Arabia: Draft tax laws for public consultation (income tax, Zakat and tax procedural)

25 Oct - Australia: Extended due date for filing country-by-country (CbC) reports, Master and Local files

25 Oct - India: Notification required for taxpayer to claim benefit under income tax treaty most favored nations clause (Supreme Court decision)

25 Oct - Israel: New deadline for first wave of e-invoicing mandate

24 Oct - Belgium: FAQ on new obligations of digital platform operators (DAC7)

24 Oct - Poland: Real estate tax on parking space; re-registering sole proprietorship as private limited company; revenue under employment contract (court decisions)

24 Oct - Sweden: VAT apportionment rules violate of EU law (Supreme Administrative Court decision)

23 Oct - United States: Illinois (Chicago real estate transfer tax); Florida (communications services tax); Massachusetts (local option real estate transfer fees); New Mexico (taxation of digital advertising)

23 Oct - United States: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals (updated with new reports)

23 Oct - United States: No change to list of countries cooperating with international boycott

23 Oct - United States: Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2023

23 Oct - France: Withholding tax on dividends to nonresident loss-making companies upheld (Constitutional Court decision)

23 Oct - Korea: Services fee arrangement satisfied arm’s length principle (Tax Tribunal decision)

23 Oct - Korea: “Transfer pricing adjustment” under supply contract not “subsequent proceeds” for customs purposes (Supreme Court decision)

23 Oct - Portugal: Individual income tax on interest paid by foreign banks incompatible with EU law (CJEU judgment)

23 Oct - Switzerland: Transfer pricing adjustment invalid because inconsistent with OECD guidelines (Federal Administrative Court decision)

23 Oct - Ukraine: Reduced withholding tax under Cyprus treaty denied because recipient not considered beneficial owner (court decision)

20 Oct - Cyprus: Deadline for filing appeal for individual income taxes extended

20 Oct - Switzerland: Refund claim for withholding tax on government bond interest denied due to cross-currency swap (Federal Administrative Court decision)

20 Oct - United States: IRS announces new compliance initiatives aimed at large corporations

20 Oct - United States: IRS LB&I division memorandum to employees on compliance priorities

19 Oct - United States: IRS announces special withdrawal process for employer retention credit claims

19 Oct - United States: Mortality table for use in determining minimum present value for 2024

19 Oct - United States: Questions remain on Superfund excise tax compliance

19 Oct - Australia: Charge for use of zero or low emissions vehicle on “specified roads” deemed invalid (Victoria)

19 Oct - France: New deadlines for implementation of e-invoicing

19 Oct - Nigeria: Taxpayer’s deductions for bad debts allowed, but deductions for public relations disallowed (Tax Appeal Tribunal decision)

18 Oct - Barbados: Guidance on deregistration of entities from AEOI portal

18 Oct - EU: Additional customs duties on certain lighters from United States annulled (CJEU General Court judgment)

18 Oct - United States: Sanctions on Hamas members, operatives, financial facilitators

18 Oct - United States: Self-insured health insurance annual fee

17 Oct - Belgium: Public country-by-country reporting draft law approved

17 Oct - Chile: Dividend, capital gains not subject to VAT; other direct and indirect tax developments

17 Oct - Côte d'Ivoire: Simplified VAT compliance mechanism for nonresident digital service providers

17 Oct - EU: New directive on tax transparency rules for service providers facilitating cryptoasset transactions

17 Oct - EU: Updates to list of non-cooperative jurisdictions

17 Oct - KPMG report: Mexico’s reference effective tax rates aid voluntary compliance

17 Oct - KPMG report: Multilateral conventions on Amount A of Pillar One and Pillar Two subject to tax rule, initial observations and analysis

17 Oct - Nigeria: Guidelines on nature and scope of tax compliance inquiry processes

17 Oct - Poland: Individual ruling denied; tax-deductible costs; qualified R&D income; qualified employment income; taxable permanent establishment (court decisions)

17 Oct - Poland: New electronic templates for transfer pricing reporting

17 Oct - United States: Government files brief in Moore case

16 Oct - Cyprus: Deadline for filing date of individual’s tax return, self-assessment extended to 31 October 2023

16 Oct - United States: Analysis of relief provisions of Rev. Proc. 2013-30 for late S corporation elections

16 Oct - United States: FBAR filing deadline relief for filers affected by terroristic action in Israel

16 Oct - United States: IRS announcement of new large partnership audits

16 Oct - United States: IRS provides tax relief for taxpayers in California affected by winter natural disasters

16 Oct - United States: New Jersey (guidance on various corporation business tax issues); Wisconsin (transfer of title constituted sale for sales tax purposes)

16 Oct - United States: Voluntary and mandatory disclosure requirements and options

13 Oct - United States: IRS provides relief for taxpayers affected by terroristic action in Israel

13 Oct - Australia: Draft determination on application of GST to combination food products

13 Oct - Portugal: Introductory gift does not constitute separate VAT-taxed (deemed) supply of goods (CJEU judgment)

13 Oct - United States: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals

13 Oct - United States: IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals

12 Oct - United States: Disallowance of section 168(k) additional first-year allowance for depreciation for “excepted trade or business” (Chief Counsel legal advice memo)

12 Oct - United States: Supreme Court schedules oral arguments in Moore case for 5 December

12 Oct - Cyprus: Status of bilateral Competent Authority Arrangement for exchange of CbC reports with United States

12 Oct - Italy: Registry of ultimate beneficial owners now operational, reporting deadline of 11 December 2023

12 Oct - Malta: Reduced VAT rate on certain services effective 1 January 2024

12 Oct - Singapore: GST Comptroller decision denying input tax claim upheld

11 Oct - Costa Rica: Tax compliance obligations for dissolved entities

11 Oct - OECD: Multilateral convention to implement Amount A of Pillar One; implementation handbook for Pillar Two global minimum tax

11 Oct - Poland: Foodstuffs containing same main ingredient may be subject to different reduced VAT rates (CJEU judgment)

11 Oct - Poland: Guidance on transfer pricing cost-plus method

11 Oct - United States: Treasury request for public input on OECD multilateral convention to implement Amount A of Pillar One

10 Oct - Czech Republic: Deadline for filing additional tax return for lower tax (Supreme Administrative Court decision)

9 Oct - Ireland: Updated FAQs on CRS implementation

9 Oct - United States: California (application of P.L. 86-272 to internet sellers); Florida (electronically delivered software not subject to sales tax); Massachusetts (corporate excise tax); Tennessee (sales tax on place of amusement)

6 Oct - United States: Guidance on transfer of clean vehicle credits under sections 25E and 30D

6 Oct - Bahamas: Updated FATCA and CRS reporting deadlines

6 Oct - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for September 2023

6 Oct - Germany: New guidance on entrepreneurial status and input VAT deductions for research institutions

6 Oct - KPMG report: Mexican-sourced technical assistance payments subject to withholding tax under Netherlands treaty (Federal Tax Court decision)

6 Oct - United States: Additions to Export Administration Regulations (EAR) entity list

5 Oct - Australia: Guidance on CRS circumvention schemes

5 Oct - Austria: Updated DAC6 guidance

5 Oct - Cyprus: Extension of deadline for VAT returns

5 Oct - India: Taxpayer eligible for tax sparing credit under Oman treaty (Supreme Court decision)

5 Oct - Latvia: Public country-by-country reporting legislation approved

5 Oct - UAE: Updated CRS guidance

5 Oct - United States: IRS updates “public key” for FATCA filing

5 Oct - United States: Purchaser of foreign goods not an “importer” liable for excise tax under section 4071 (federal district court)

4 Oct - United States: IRS TE/GE 2024 program letter

4 Oct - United States: Penalties on unfiled annual reconciliation of apportionable income (Washington State)

4 Oct - Brazil: New transfer pricing rules published

4 Oct - KPMG report: Deregistering “dead” FATCA and CRS entities

4 Oct - Malaysia: Updated e-invoicing guidelines

4 Oct - Poland: Insurance services not subject to lump-sum income tax; power equipment taxable as structures; recordkeeping requirements for preferential tax rate (Supreme Administrative Court decisions)

4 Oct - Poland: Public consultations on beneficial owner for withholding tax purposes, expansion relief measures

3 Oct - Belgium: B2B e-invoicing mandatory effective 1 January 2026

3 Oct - Japan: Guidance on income inclusion rule

3 Oct - OECD: Multilateral convention to facilitate implementation of Pillar Two subject to tax rule

3 Oct - KPMG report: Comments in response to EC public consultation on proposal to improve withholding procedures (FASTER)

3 Oct - KPMG report: Effect of EU small business VAT reform on nonresidents and large businesses

3 Oct - United States: IRS request for information on requiring health insurance coverage of over-the-counter preventive items under Affordable Care Act

3 Oct - United States: House Ways and Means to mark up disaster tax relief bill; JCT description

2 Oct - United States: Foreign tax credit—categorization of income and taxes into proper basket (IRS practice unit updated 1 August)

2 Oct - United States: Iowa (reduced corporate income tax rates); Massachusetts (pending tax law changes, including for corporate excise tax); Oregon (Portland business license tax credit); Texas (sales and use tax guidance for electronic games)

September 2023

29 Sep - Slovakia: Guidance on proving identity of beneficial owner of income

29 Sep - Spain: EC decision of unlawful State aid annulled to protect legitimate expectations (CJEU General Court judgment)

29 Sep - United States: Additional guidance on beneficial ownership information reporting requirements

29 Sep - United States: IRS Priority Guidance Plan for 2023-2024

29 Sep - United States: IRS provides tax relief for taxpayers in Louisiana affected by seawater intrusion

29 Sep - United States: IRS TE/GE division provides two new technical guides

29 Sep - United States: Wash sale relief for certain redemptions of shares in money market funds

28 Sep - Japan: 2023 tax reform amendments to electronic preservation system for account books

28 Sep - OECD: MLI signed (Eswatini); instrument of ratification of MLI deposited (Côte d'Ivoire)

28 Sep - United States: Guidance on employer leave-based donation programs aiding Hawaii wildfire victims

28 Sep - United States: IRS contingency plan during possible government shutdown

28 Sep - United States: New CAMT guidance in Notice 2023-64 expands scope, increases compliance burdens

27 Sep - United States: 30-day time limit for requesting collection due process hearing subject to equitable tolling (U.S. Tax Court)

27 Sep - United States: Application period for environmental justice solar and wind capacity limitation program opens 19 October

27 Sep - United States: Extended filing deadline for certain beneficial ownership information reports

27 Sep - United States: Farmers, ranchers affected by drought allowed more time to replace livestock

27 Sep - United States: Guidance on new energy efficient home credit under section 45L

27 Sep - United States: Guidance on procedural requirements for section 5000D excise tax on sales of “designated drugs”

27 Sep - India: Buyback of shares subject to dividend distribution tax (tribunal decision)

26 Sep - Poland: Amendments to decrees on transfer pricing reporting now effective

26 Sep - Poland: Look-through approach for dividend exemption; tax treatment of losses incurred by Romanian branch; no VAT on stolen goods (court decisions)

26 Sep - Poland: Tax consequences of issuing fake invoice by employee without knowledge of employer (CJEU Advocate General opinion)

26 Sep - Australia: Guidance on correcting GST and fuel tax errors for prior tax periods

26 Sep - Austria: Summary of recent direct and indirect tax developments

26 Sep - South Africa: Cancellations of customs-related registrations and licences

26 Sep - United States: DHS updates Uyghur Forced Labor Prevention Act (UFLPA) entity list

25 Sep - Korea: Fee paid to foreign parent company was royalty subject to withholding tax (Tax Tribunal decision)

25 Sep - Korea: Products provided free of charge under purchase agreement were not “free of charge imports” (Supreme Court decision)

25 Sep - United States: Additions, revisions to Export Administration Regulations (EAR) entity list

25 Sep - United States: Initial observations on round 4 of CAMT guidance in Notice 2023-64

25 Sep - United States: IRS provides tax relief for taxpayers in Maine and Massachusetts affected by Hurricane Lee

25 Sep - United States: Missouri (sales tax collection); North Carolina (sourcing rules); Tennessee (sales and use tax industrial machinery exemption); Washington State (manufacturing B&O tax)

25 Sep - United States: Per diem rates, substantiation of employee lodging, meals, incidentals (2023-2024)

21 Sep - United States: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

21 Sep - United States: Claims court erred in applying hybrid legal standard conflating step transaction and economic substance doctrines (Federal Circuit)

21 Sep - Canada: Deadline to qualify for partial loan forgiveness extended to early 2024

21 Sep - Australia: Draft legislation to improve tax system

20 Sep - Belgium: Tax exemptions granted on certain “excess” profits constitute unlawful State aid (CJEU judgment)

20 Sep - China appeals WTO panel report finding Chinese duties on U.S. products retaliatory

20 Sep - India: Reassessment notice issued without approval was time barred (High Court decision)

20 Sep - India: Taxpayer entitled to refund of taxes paid on behalf of nonresident (High Court decision)

20 Sep - Kenya: Public consultation on draft transfer pricing rules

20 Sep - OECD: Comments on public consultation document on Amount B under Pillar One

20 Sep - Saudi Arabia: Public consultation on draft regulation for Zakat collection

20 Sep - Switzerland: Elimination of tariffs on industrial goods effective 1 January 2024

20 Sep - Thailand: New interpretation of foreign-sourced income brought into Thailand by Thai tax residents

20 Sep - UK: Taxpayer acting as principal and not agent for VAT purposes (First-tier Tribunal decision)

20 Sep - United States: IRS announces new work unit focused on large or complex passthrough entities to help with high-income compliance efforts

19 Sep - Denmark: Transfer pricing adjustments on intercompany transactions between oil and gas company and its subsidiaries upheld (Supreme Court decision)

19 Sep - Colombia: Suspension of certain implementing guidance under single-use plastic products tax (Supreme Tax Court decision)

19 Sep - Poland: Real estate tax imposed on fuel and gas dispensers (Supreme Administrative Court decision)

18 Sep - Belgium: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid (Constitutional Court decision)

18 Sep - France: Tax officials announce e-invoicing mandate would become effective in 2026

18 Sep - United States: Arkansas (proposed reduction in income tax rates); Florida (guidance on sales and use tax audit program); Kansas (reduction in corporate income tax rate); Oregon (guidance on P.L. 86-272); Tennessee (industrial machinery sales tax exemption)

15 Sep - United States: IRS request for comments on expanding tax certainty and issue resolution programs for business taxpayers

15 Sep - United States: IRS request for feedback on proposed changes to Form 6765, Credit for Increasing Research Activities

15 Sep - Bolivia: Extended deadline for certain taxpayers to present affidavits and pay tax for August 2023

15 Sep - UK: Employers may reclaim national insurance contributions on car allowances (Upper Tribunal decisions)

15 Sep - UK: Increased scrutiny of R&D tax incentive claims

15 Sep - Australia: New communications protocol for ATO objections

14 Sep - Australia: Tax refunds will no longer be deposited into non-authorised deposit-taking institutions

14 Sep - Greece: New reporting obligations for digital platform operators (DAC7)

14 Sep - United States: IRS announces moratorium on processing new employer retention credit claims

13 Sep - United States: Initial observations and analysis of Notice 2023-63 providing guidance on section 174

13 Sep - United States: IRS provides tax relief for taxpayers in Georgia affected by Hurricane Idalia

12 Sep - United States: FBAR filing deadline relief for persons affected by certain natural disasters (Hawaii wildfires and Hurricane Idalia)

12 Sep - KPMG report: Estimating an arm’s length range for North American retailers

12 Sep - Mexico: List of 196 registered foreign providers of digital services (as of 31 August 2023)

12 Sep - United States: Additional interim guidance on new corporate alternative minimum tax (CAMT)

12 Sep - Czech Republic: Accommodation service versus lease of real estate for VAT purposes, and abuse of rights concept (municipal court decision)

12 Sep - Czech Republic: Tax deductibility of management services (Supreme Administrative Court decision)

11 Sep - Czech Republic: Guidance on application of VAT to gratuitous supplies of goods

11 Sep - Bulgaria: New reporting obligation for VAT-registered persons

11 Sep - Cambodia: Procedures for requesting input VAT credits and VAT refunds

11 Sep - India: Singaporean company entitled to treaty benefits on capital gains from transfers of shares of Indian companies (tribunal decision)

11 Sep - United States: Immediate recognition of income upon constructive transfer of intangible property in reorganization; Tax Court affirmed (First Circuit)

11 Sep - United States: California (marketplace facilitator law); California (mutual fund service provider sourcing rule); New Jersey (corporation business tax nexus); New York (broker-dealer sourcing rule)

8 Sep - United States: Guidance on application of section 174

8 Sep - United States: IRS announces all QI / WP / WT applications for 2023 must be submitted through QAAMS by October 27

8 Sep - United States: IRS announces new compliance effort focused on high-income individuals, partnerships, and large corporations

8 Sep - United States: Proposed regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives

7 Sep - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for August 2023

7 Sep - United States: BIS imposes penalty to resolve violations of antiboycott rules

7 Sep - United States: Extension of product exclusions, China Section 301 investigation

7 Sep - Nigeria: Country-by-country reporting rules not validly adopted and thus unenforceable (Tax Appeal Tribunal decision)

6 Sep - Nigeria: Transfer of taxpayer’s file between tax offices was illegal (Tax Appeal Tribunal decision)

6 Sep - United States: IRS opens application period for 2024 Compliance Assurance Process (CAP) program

6 Sep - United States: IRS provides tax relief for taxpayers in South Carolina affected by Hurricane Idalia

5 Sep - United States: IRS releases FAQ for pass-through entities for electronically filing Schedules K-2 and K-3 to report negative amounts

5 Sep - Poland: Insurance services not guarantee services subject to lump-sum tax (Supreme Administrative Court decision)

5 Sep - UK: Interest deductions on intra-group debt disallowed on grounds of unallowable purpose (Upper Tribunal decision)

5 Sep - UK: HMRC guidance on advance pricing agreements

1 Sep - KPMG report: Comments on public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

1 Sep - Cyprus: Submission of company income statements and self-employed with accounts due 31 March 2024

1 Sep - EU: Enhanced enforcement of VAT rules on non-resident digital economy businesses

1 Sep - Seychelles: Changes to transfer pricing rules

August 2023

31 Aug - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Idalia

30 Aug - Channel Islands: Closure of FATCA and CRS reporting portal (Jersey)

30 Aug - Portugal: Public country-by-country reporting legislation approved

30 Aug - United States: Guidance on state and local tax refunds and other payments to individuals

30 Aug - United States: IRS provides tax relief for taxpayers in Alaska affected by flooding

29 Aug - United States: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

29 Aug - Netherlands: Draft legislation implementing public country-by-country reporting

29 Aug - Poland: Application of general anti-abuse rule; taxation of restricted stock; taxation of company conversion (Supreme Administrative Court decisions)

29 Aug - Poland: Extended deadline for tax on unrealized gains; guidance on capital duty

29 Aug - EU: Certain carbon border adjustment mechanism rules challenged before CJEU

29 Aug - Luxembourg: Beneficial ownership of trademark (court decision)

29 Aug - Spain: Burden of proving abuse of withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision)

29 Aug - United Kingdom: Policy paper on reporting obligations for digital platform operators (DAC7)

28 Aug - Anguilla: Suspension of tax information exchange with Russia and Belarus

25 Aug - United States: Guidance on new Roth catch-up requirement, including administrative transition period

25 Aug - United States: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2023)

25 Aug - Australia: 12-month pause for general practitioners payroll tax audits (New South Wales)

25 Aug - Bolivia: Deadline to implement online invoicing modalities postponed for fourth, fifth, and sixth groups of taxpayers

25 Aug - Canada: Updated FATCA and CRS guidance

25 Aug - United States: IRS updates 2023 Form 1042-S instructions

24 Aug - Mauritius: New income tax treaty with Hong Kong entered into force

24 Aug - United States: IRS updates FAQ extending penalty relief, Forms 1042 and 1042-S

24 Aug - United States: Fourth quarter update to IRS 2022-2023 Priority Guidance Plan

23 Aug - United States: Premium tax credit percentage table for 2024

23 Aug - Australia: ATO requesting information on corporate tax transparency data for large companies

23 Aug - Barbados: Further extension of FATCA and CRS filing deadline to 8 September 2023

23 Aug - Israel: Guidance on competent authority, mutual agreement, and bilateral APA procedures

23 Aug - Saint Vincent and the Grenadines: Further extension of FATCA and CRS reporting deadline to 25 August 2023

23 Aug - Tunisia: Instrument of ratification of MLI deposited with OECD

22 Aug - Poland: Tax-deductible costs; income from IP and credit default swaps (court decisions)

22 Aug - Saudi Arabia: Eighth wave of e-invoicing applicability

21 Aug - United States: IRS provides tax relief for taxpayers affected by wildfires in Hawaii

21 Aug - United States: No change to list of countries cooperating with international boycott

21 Aug - United States: Pennsylvania (lookback period for voluntary disclosure agreement program); Tennessee (employment services not subject to sales and use tax)

21 Aug - Korea: Customs value of goods imported from bonded area (Supreme Court decision)

21 Aug - Korea: Proposed amendments to transfer pricing and Pillar Two rules

18 Aug - Bolivia: Digital notification of administrative acts

18 Aug - UAE: Conditions for qualifying investment funds to be exempt from corporate tax

18 Aug - United States: Oil and gas—reference prices for 2023, inflation adjustment factor and phase-out for enhanced oil recovery credit

17 Aug - Bahrain: Economic substance filing window open from 13 August to 13 September 2023

17 Aug - Canada: Provincial sales tax annual information return due 31 August for online marketplaces (British Columbia)

16 Aug - Denmark: Increase in VAT audits of nonresident digital services providers

16 Aug - Denmark: Interest on corrections of VAT and excise duties for past periods effective 1 July 2023

16 Aug - Philippines: VAT refund guidelines

16 Aug - Poland: Mandatory e-invoicing legislation enacted

16 Aug - Poland: Tax on revenue from buildings; VAT treatment of preliminary land sale contract; social media barter contract (court decisions)

16 Aug - WTO panel report finds China’s additional duties on U.S. imports inconsistent with WTO agreement

16 Aug - United States: IRS provides tax relief for taxpayers in Illinois affected by storms

15 Aug - United States: IRS provides tax relief for taxpayers in Mississippi affected by storms

15 Aug - Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules

15 Aug - Dominican Republic: Draft rule on appointment of VAT and income tax withholding and collection agents

15 Aug - United States: Select financial product provisions in Biden Administration’s FY 2024 budget

14 Aug - Canada: Prescribed rates of interest for income tax, PLOI purposes (fourth quarter 2023)

14 Aug - KPMG report: Accelerated competent authority procedure can extend MAP resolutions to subsequent years

14 Aug - United States: New Jersey (convenience of employer rule); New York (corporate franchise tax); South Carolina (method of apportionment)

11 Aug - United States: Availability of administrative exemptions from requirement to file electronically

10 Aug - Barbados: Further extension of FATCA and CRS filing deadline to 11 August 2023

10 Aug - Korea: Tax reform proposal for 2023, changes to Pillar Two and transfer pricing documentation rules

10 Aug - United States: Guidance on environmental justice solar and wind capacity limitation

9 Aug - United States: Deduction for assumed deferred compensation liabilities not allowed when not paid; Tax Court affirmed (Seventh Circuit)

9 Aug - India: CRS clarifications

9 Aug - Mexico: Agreement for collection of lodging taxes (Nuevo Leon)

9 Aug - OECD: Cryptoasset reporting framework (CARF) updates and CRS amendments

9 Aug - Philippines: Scanned copies of expenses do not satisfy tax deductibility requirements

8 Aug - Mauritius: Tax amnesty program renewed

8 Aug - Poland: Costs of foreign posting; withholding on foreign payments; increased real estate tax (court decisions)

8 Aug - United States: Exaction related to employer mandate under Affordable Care Act is a tax for jurisdictional purposes (D.C. Circuit)

8 Aug - United States: IRS adds a new compliance campaign (LB&I division)

8 Aug - WTO panel reports on disputes between India and United States, mutually agreed solutions

7 Aug - Australia: Audit on ATO’s management of transfer pricing for related-party debt

7 Aug - Australia: Review of regulatory frameworks for tax services and large consulting, accounting, and auditing firms

7 Aug - Ghana: Direct and indirect tax administration provisions in 2023 mid-year budget review

7 Aug - India: Payments for cloud computing services not taxable royalties or fees for technical services under U.S. tax treaty (tribunal decision)

7 Aug - India: Reassessment notice based on contradictory advance ruling for another taxpayer was invalid (High Court decision)

7 Aug - UK: Guidance on corporation tax relief for cost of net-settled and cash cancelled employee share awards

7 Aug - United States: California (apportionment formula); Michigan (sales factor, taxation of digital goods); New Hampshire (deduction for disallowed interest); Ohio (oil and gas sales and use tax exemption)

4 Aug - United States: Guidance on qualification of home energy audits for energy efficient home improvement credit under section 25C

4 Aug - United States: Guidance on section 5000D excise tax on sales of “designated drugs”

4 Aug - Belgium: Overview of APA system

4 Aug - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for July 2023

4 Aug - Croatia: Implementation of public country-by-country reporting

4 Aug - EU: Formal notice to 14 member states of failure to implement public country-by-country reporting

4 Aug - EU: Reasoned opinion to six member states on failure to fully transpose DAC7

4 Aug - Hong Kong: Latest proposals on tax certainty scheme for onshore equity disposal gains and expanded foreign-sourced income exemption regime

4 Aug - Hungary: Formal notice of failure to align corporate income tax rules with ATAD

4 Aug - Italy: Taxpayer not respected as beneficial owner of interest payments (Supreme Court decision)

4 Aug - Luxembourg: Referral to CJEU by European Commission for failure to correctly transpose ATAD interest limitation rules

4 Aug - UAE: Implementation of new tax procedures executive regulation

3 Aug - United States: Draft forms provide insight into compliance burden imposed by new CAMT

3 Aug - United States: Monetized installment sale transactions identified as listed transactions

3 Aug - KPMG report: Amount B and tax certainty

3 Aug - Sri Lanka: Extended due date for filing quarterly advance income tax statements

2 Aug - South Africa: Proposed APA program

1 Aug - Bolivia: Online billing modality for “fourth group of taxpayers” further postponed

1 Aug - Bolivia: Online billing modality for “fifth group of taxpayers” postponed

1 Aug - Poland: Recordkeeping for IP Box relief; cash as tax-deductible cost; residential property used in business; taxation of agricultural prizes (Supreme Administrative Court decisions)

1 Aug - Australia: ATO Corporate Plan focuses on collectible debts

1 Aug - Bulgaria: Amendments to beneficial owners registry law

1 Aug - Germany: Updated CRS guidance, final state exchange list

1 Aug - United States: Validating Form W-8BEN and BEN-E treaty claims

July 2023

31 Jul - EU: Public country-by-country reporting implementation summary

31 Jul - Korea: Amendments to “Method 4” for determining customs value

31 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Canada and Mexico

31 Jul - Saudi Arabia: Seventh wave of e-invoicing applicability

31 Jul - United States: California (sales tax audit methods); New Jersey (convenience of employer rule); Oklahoma (franchise tax returns): Texas (franchise tax reports)

31 Jul - United States: Cryptocurrency rewards included in income when taxpayer gains dominion and control over rewards

28 Jul - United States: IRS clarifies position on employee retention credit supply chain disruptions (generic legal advice memorandum)

28 Jul - France: Delay in e-invoicing and e-reporting implementation

28 Jul - Kenya: KRA must issue objection decision within 60 days (court decision)

28 Jul - Portugal: Updated FATCA and CRS user manuals

28 Jul - Vietnam: Expediting VAT refunds

27 Jul - United States: IRS request for comments on dispute resolution programs

27 Jul - United States: Accounting for income taxes considerations for foreign tax credits following Notice 2023-55

27 Jul - United States: Legal expenses for defending patent infringement suits are deductible (Third Circuit)

27 Jul - Bahrain: VAT return filing and payment deadline extended to 1 August 2023

27 Jul - Luxembourg: VAT treatment of activities carried out by board member (CJEU Advocate General opinion)

26 Jul - United States: CBP adjusts customs user fees for inflation (FY 2024)

26 Jul - United States: Procedures for voluntarily self-disclosing violations of U.S. sanctions and export control laws

26 Jul - Saudi Arabia: Penalty waiver for taxes, including VAT and excise tax, extended through December 2023

25 Jul - KPMG report: New guidance on Pillar Two rules, initial observations and analysis

25 Jul - KPMG report: Public consultation on Amount B under Pillar One, initial observations

25 Jul - KPMG report: OECD’s effort to simplify transfer pricing

25 Jul - United States: IRS TE/GE division provides four new technical guides

25 Jul - United States: Percentage depletion for oil and gas produced from marginal properties; electricity production credit

24 Jul - United States: California (tax on lease of tangible personal property); Mississippi (computer software direct pay permits)

24 Jul - UK: Transfer pricing records regulations published

24 Jul - Ireland: Updated FATCA, CRS guidance for AEOI

24 Jul - Japan: Updated FAQs under CRS regime

21 Jul - Antigua and Barbuda: FATCA, CRS reporting deadlines extended to 19 September 2023

21 Jul - Australia: Determination on GST, wine tax, luxury car tax for defence-related international obligations

21 Jul - Korea: Payments treated as expenses under cost sharing agreement and not royalties (Administrative Court decision)

21 Jul - Malaysia: Guideline for implementation of e-invoicing

21 Jul - United States: Temporary relief for foreign tax credit under sections 901 and 903

20 Jul - KPMG report: Latest Pillar Two guidance provides some relief for U.S. multinationals, but concerns remain

20 Jul - Singapore: Profits method used to value property for property tax purposes

19 Jul - United States: 90-day time limit to file deficiency petition is not jurisdictional and thus subject to equitable tolling (Third Circuit)

19 Jul - Australia: Draft instrument on correcting fuel tax errors

19 Jul - Dominican Republic: Draft law modifying tax assessment, audit and payment procedures

19 Jul - Luxembourg: U.S. branch denied permanent establishment status (administrative court decision)

19 Jul - Poland: Preferential corporate rate; residential depreciation repeal; deductibility of certain expenses (Supreme Administrative Court decisions)

19 Jul - South Africa: Updated PAYE administrative penalties

19 Jul - UAE: FATCA, CRS risk assessment questionnaire user guide

18 Jul - United States: Letters sent inviting companies to join unclaimed property voluntary disclosure agreement program, 90 days to respond (Delaware)

18 Jul - Australia: Guidance on claiming research and development tax incentives

18 Jul - United States: Additions to Export Administration Regulations (EAR) entity list

18 Jul - United States: Underutilization of alternative dispute resolution programs

17 Jul - United States: Manufacturer of defense weapon systems and defense contractor agree to settle violations of antiboycott regulations

17 Jul - Germany: CRS reporting deadline extended to 31 August 2023

17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules

17 Jul - OECD: Public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

14 Jul - United States: Transition relief and guidance related to certain required minimum distributions

14 Jul - United States: Notice of filing of petition for addition of methyl ethyl ketoxime to Superfund list

13 Jul - France: New transfer pricing measures announced for 2024 Draft Finance Bill

13 Jul - Thailand: Guidance for taxpayers within scope of Pillar Two global minimum tax rules

13 Jul - India: Payments on account of seconded employees not taxable as "fees for technical services" (tribunal decision)

13 Jul - Saudi Arabia: Guidelines on tax rulings

13 Jul - United States: IRS practice unit: Expatriation on or after 17 June 2008—mark-to-market tax regime

13 Jul - United States: IRS provides tax relief for taxpayers in Vermont affected by flooding

13 Jul - KPMG report: Implications of the Inflation Reduction Act and CHIPS Act for U.S. importers

12 Jul - EU: European Commission progress report on Pillar One

12 Jul - Germany: Draft bill implementing Pillar Two global minimum tax

12 Jul - Italy: Withholding tax on dividends paid to investment fund breaches EU law, refund granted (court decision)

12 Jul - Latvia: Updated list of non-cooperative jurisdictions

12 Jul - Liechtenstein: Consultation on implementation of public country-by-country reporting

12 Jul - Malta: Guidance on DAC7

12 Jul - Netherlands: Proposed amendments to tax ruling policy

12 Jul - OECD: Outcome statement on BEPS 2.0

12 Jul - UK: HMRC removes requirement for UK companies to make annual country-by-country reporting notification

11 Jul - Barbados: FATCA and CRS filing deadline extended to 2 August 2023

11 Jul - Canada: New mandatory disclosure rules clarified

11 Jul - Canada: Updated list of imported goods targeted for potential audits

11 Jul - Nigeria: Extended deadline for filing companies income tax returns for 2023

11 Jul - Poland: Mobile application for e-invoicing; consultation on schemas for digital platform operators (DAC7)

11 Jul - South Africa: Further information required on section 18A donation receipts

10 Jul - United States: Carryback of consolidated net operating losses

10 Jul - Australia: Taxpayer’s “food” product subject to GST (Administrative Appeals Tribunal decision)

10 Jul - Australia: Procedural rules for digital games tax offset; regulations to enable compensation scheme of last resort; regulations for new registrable superannuation entity reporting requirements 

10 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Germany, the Netherlands, and Sweden

10 Jul - Mexico: Guidance on social security tax practices

10 Jul - Oman: Income tax treaty with Egypt signed

10 Jul - Panama: List of reportable jurisdictions updated for 2023

10 Jul - UK: No UK taxing rights under UK-Canada treaty on UK oil field production profits paid to non-resident (Court of Appeal judgment)

7 Jul - Brazil: Public consultation on new transfer pricing rules

7 Jul - Luxembourg: Updated FAQ on mandatory disclosure rules (DAC6)

7 Jul - Philippines: Running of prescriptive period for VAT, applicability of VAT to interest income from affiliated loans (Supreme Court decision)

7 Jul - Poland: Definition of structure for real estate tax purposes held unconstitutional (Constitutional Tribunal decision)

7 Jul - Spain: Deadline to claim VAT refunds for 2022 is 30 September 2023

7 Jul - South Africa: Persons required to submit third party returns

6 Jul - United States: Section 41 research tax credit denied, accuracy-related penalties imposed (U.S. Tax Court)

6 Jul - United States: Partnership losses claimed on unsigned, unfiled tax returns disallowed; Tax Court reversed (Ninth Circuit)

6 Jul - Australia: Report on review of advance pricing agreement program

6 Jul - Australia: Research and development tax incentives claim denied (Federal Court decision)

6 Jul - India: Guidance on withholding tax on purchases of overseas tour packages and foreign remittances

6 Jul - Ireland: Extension of FATCA and CRS filing deadline

5 Jul - Australia: Updated guidance on residency central management and control test, including new risk-free assessment framework

5 Jul - Chile: U.S. income tax treaty approved by U.S. Senate

5 Jul - India: Capital gain exempt under Singapore treaty (High Court decision)

3 Jul - United States: Period of limitations for assessing tax on partnership items expired (U.S. Tax Court)

June 2023

30 Jun - United States: Distributive shares of partnership income from sale of partnership assets is patronage-sourced income (PLR)

30 Jun - India: Tax residency certificate for claiming tax treaty benefits; tax withheld at source under liberalised remittance scheme and overseas tour program package

30 Jun - UAE: Updated FATCA, CRS guidance and policy manual

29 Jun - Bolivia: “Fifth group of taxpayers” to implement online billing modality

29 Jun - Panama: CRS reporting deadline extended to 15 August 2023

29 Jun - Philippines: Distributions on depository receipts taxed as interest, not dividends

29 Jun - Romania: Amendments to public country-by-country reporting rules

29 Jun - United States: Taxpayers not required to report or pay stock repurchase excise tax before time specified in forthcoming regulations

28 Jun - Australia: Draft guidance on interaction of non-arm’s length income and capital gains, control and residency tests

28 Jun - France: Implementation of public country-by-country reporting

28 Jun - Germany: Updated transfer pricing guidelines; U.S. agreement on automatic exchange of country-by-country reporting

28 Jun - Lithuania: Country-by-country reporting directive transposed into domestic law

28 Jun - Luxembourg: Guidance on reverse hybrid rules

28 Jun - OECD: Updated guidelines for multinational enterprises, final cryptoasset reporting framework rules

28 Jun - Poland: Reducing depreciation during period of State aid not tax evasion; invoices issued prematurely not fictitious

28 Jun - United States: Coordinated export control enforcement (Australia, Canada, New Zealand, United Kingdom, United States)

27 Jun - United States: Analysis and observations of direct pay and transferable credit proposed regulations

27 Jun - Australia: Overhead costs apportioned to GST-free supplies entitled to input tax credits (Federal Court decision)

27 Jun - Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax

27 Jun - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (June 2023)

27 Jun - OECD: Tax transparency in Latin America 2023

26 Jun - Australia: Delay in implementation of public country-by-country (CbC) reporting

26 Jun - Belgium: Income tax treaty with Netherlands signed

26 Jun - KPMG report: Transfer pricing methods for asset management sub-advisers

26 Jun - UK: Consultation on transfer pricing, permanent establishment, and DPT rules

26 Jun - UK: Deduction denied for payments on related-party indebtedness (First-tier Tribunal decision)

26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested

26 Jun - UK: Updated guidance on anti-avoidance rules for creative sector tax reliefs

26 Jun - United States: Alabama (monthly sales tax filing threshold); Michigan (memo not a request for refund); Texas (sales and use tax exemptions); Washington State (data processing)

26 Jun - United States: Foreign tax credit—categorization of income and taxes into proper basket

26 Jun - United States: State, local tax changes (second quarter 2023, table format)

26 Jun - United States: Supreme Court grants certiorari, whether mandatory repatriation tax under section 965 is constitutional

23 Jun - United States: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2023

23 Jun - United States: Guidance related to COVID-19 for purposes of high-deductible health plans

23 Jun - United States: Reference price for enhanced oil recovery credit, marginal oil and gas production

23 Jun - United States: Value of anticipated cash grants are separate intangible assets for purchase price allocation purposes (U.S. Court of Federal Claims)

23 Jun - Chile: Extension of deadline for filing transfer pricing affidavits

23 Jun - Costa Rica: Updated list of cross-border digital service providers

23 Jun - Korea: Imported plastic toys that can be assembled and disassembled subject to 0% tariff rate (Tax Tribunal decision)

23 Jun - Korea: Imputation of arm’s length interest on accounts receivable from foreign affiliate was reasonable (Tax Tribunal decision)

21 Jun - KPMG reports: Transfer pricing considerations in mergers and acquisitions, focus on UK

21 Jun - OECD: Continued progress on harmful tax practices

21 Jun - Poland: Invoices issued prematurely not fictitious; documentation of business in special economic zone (Supreme Administrative Court decisions)

21 Jun - Poland: Reduced VAT on food extended; mandatory e-invoicing; revocation of state of health emergency

21 Jun - Saudi Arabia: Criteria for sixth group of taxpayers to comply with second phase of e-invoicing implementation

21 Jun - Switzerland: Implementation of Pillar Two minimum tax approved by public vote

21 Jun - United States: JCT analysis of possible effects of Pillar Two global minimum tax adoption

21 Jun - United States: National Taxpayer Advocate mid-year report to Congress identifying key objectives for upcoming fiscal year

21 Jun - United States: Passthrough net operating loss carryovers disallowed due to insufficient basis (U.S. Tax Court)

21 Jun - United States: Senate votes to invoke cloture on income tax treaty with Chile

20 Jun - Australia: Consultation on non-arm’s length income provisions amendments

20 Jun - EU: European Commission proposal to improve withholding tax procedures

20 Jun - Hong Kong: Advance rulings under foreign-sourced income exemption regime

20 Jun - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on France, Italy, and Spain

20 Jun - KPMG report: Transfer pricing considerations for ESG-related intangible assets

20 Jun - Luxembourg: Instructions related to TIN field issued

20 Jun - South Korea: Revised CRS regulations

20 Jun - Spain: Draft e-invoicing regulations published

16 Jun - EU: ECOFIN report addressing “Unshell” Directive, DAC8, automatic exchange of information

16 Jun - Chile: Obligation to issue tax receipts for all transactions, regardless of amount

16 Jun - Norway: Draft legislation implementing Pillar Two minimum tax

16 Jun - Poland: Interest required to be paid on unduly withheld taxes (CJEU judgment)

15 Jun - Poland: Amendments to simplify and accelerate VAT settlements, including “Slim 3 VAT package”

15 Jun - Poland: Revenue from business in special economic zone; deduction of VAT in cross-border transactions and residential leases (Supreme Administrative Court decisions)

15 Jun - Australia: Overview on key FY 2022-2023 changes for tax professionals

15 Jun - Australia: Requirements of recipient created tax invoice for GST purposes

15 Jun - Brazil: OECD-aligned transfer pricing rules signed by president

15 Jun - Canada: Budget 2023 general anti-avoidance rule consultation, KPMG comments

15 Jun - Netherlands: Denial of dividend withholding tax exemption under anti-abuse provision upheld (CJEU Advocate General opinions)

15 Jun - United States: Updated annual list of automatic accounting method changes

15 Jun - United States: Updated guidance on requirements for energy community production and investment tax credits

14 Jun - United States: Treasury and IRS release guidance on direct pay and transferable tax credits

14 Jun - British Virgin Islands: Revised updates on reporting U.S. TIN codes for FATCA purposes

14 Jun - Cyprus: Deadline for filing date of individual’s tax return, self-assessment extended to 2 October 2023

14 Jun - Denmark: Public country-by-country reporting legislation passed

14 Jun - Nigeria: Federal Inland Revenue Service empowered to appoint non-resident suppliers as agents of VAT collection (Tax Appeal Tribunal)

14 Jun - Saint Vincent and the Grenadines: Extended FATCA and CRS reporting deadline

14 Jun - Singapore: High Court dismisses appeal, holds that cement silo is not a “plant” for capital allowance purposes

14 Jun - South Africa: Third-party data annual submissions process for AEOI closed

13 Jun - Italy: Updated FATCA, CRS technical guidance

13 Jun - Kenya: Declaration of related-party or controlled transactions on income tax company returns

13 Jun - Saudi Arabia: Proposed amendments to tax and Zakat regulations for public consultation purposes

13 Jun - UAE: Updated FATCA, CRS system registration user guide

12 Jun - Canada: Consultation on proposed transfer pricing rules

12 Jun - Hong Kong: Changes to issuance of certificate of residence status and application forms

12 Jun - Hong Kong: Update on profits tax, BEPS 2.0, and e-filing

12 Jun - KPMG report: Brazil’s proposed transfer pricing rules, implications for intercompany financial transactions

12 Jun - Liechtenstein: Updated FATCA guidance concerning U.S. TINs

12 Jun - UK: Importance of commercial reality in assessing withholding tax obligations (Upper Tribunal decision)

12 Jun - UK: New accruals framework for carried interest

12 Jun - UK: Treasury “call for evidence” on employee save-as-you-earn and share incentive plans

12 Jun - United States: Connecticut (corporate surcharge extension); Illinois (investment partnership status changes); Louisiana (sales tax economic nexus threshold change); Mississippi (no good faith basis for exempt sales); Oklahoma (franchise tax repealed)

12 Jun - United States: Revisions to Export Administration Regulations (EAR) entity list

12 Jun - United States: Tax treatment of employer-funded, fixed-indemnity insurance policy (Chief Counsel legal advice memo)

12 Jun - United States: Treasury, OMB agreement no longer requires OIRA review for tax regulatory actions issued by IRS

9 Jun - United States: Organizations developing NIL opportunities for student-athletes generally will not qualify as tax-exempt

9 Jun - United States: Ways and Means Chairman Smith releases three tax bills

9 Jun - Australia: Final ruling regarding deductibility of labor costs relating to capital assets

9 Jun  - Cambodia: New law on taxation

9 Jun - Saint Kitts and Nevis: FATCA and CRS reporting deadline extended to 29 August 2023

8 Jun - Canada: QST annual information return for distribution platform operators due 30 June (Quebec)

8 Jun - Canada: Mutual agreement procedure (MAP) statistics for 2021

8 Jun - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU Advocate General opinion)

7 Jun - United States: “Country of origin” ruling affects U.S. importers

7 Jun - United States: Estimated tax penalty relief for corporations subject to CAMT

7 Jun - United States: Foreign tax credit issues arising from 2022 Colombian tax reform

7 Jun - KPMG report: Transfer pricing implications of automotive innovation

6 Jun - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for May 2023

6 Jun - Dominican Republic: Law creating national tax system of electronic invoicing passed

6 Jun - France: New proposals to counter international tax fraud, including lower turnover threshold for transfer pricing documents

6 Jun - Germany: Interim findings and outcomes from mandatory disclosure rules (DAC6) reporting

6 Jun - Luxembourg: Draft law implementing DAC7

6 Jun - Malaysia: FAQs on re-implementation of voluntary disclosure programs

6 Jun - Spain: Bill implementing DAC7 enacted, implications for financial institutions

6 Jun - Spain: Foreign alternative investment fund entitled to refund of dividend withholding tax (Supreme Court decision)

6 Jun - United States: State nil reporting and penalty notices

6 Jun - United States: Malta personal retirement scheme transactions identified as listed transactions

5 Jun - United States: Colorado (commercial property tax valuations); Minnesota (retail delivery fee); Nebraska (corporate income tax rate reduction); Virginia (manufacturer’s apportionment formula)

5 Jun - United States: President Biden signs bill to increase debt limit, partially rescind IRS funding

5 Jun - United States: President Biden to nominate Marjorie Rollinson as IRS Chief Counsel

5 Jun - United States: Reference price for section 45I credit for production of natural gas from marginal wells

5 Jun - United States: Value of stock held by estate included life insurance proceeds intended for redemption of such stock (Eighth Circuit)

5 Jun - British Virgin Islands: No penalties for late filings due to BVIFars technical difficulties

2 Jun - Israel: Tax authority’s claim of deemed taxable transfer of functions, assets, and risks upheld (court decision)

2 Jun - United States: Senate passes bill to increase debt limit, partially rescind IRS funding; President Biden to sign

1 Jun - Malaysia: Transfer pricing and advance pricing arrangement rules 2023

1 Jun - St. Lucia: Updated FATCA TIN guidance

1 Jun - United States: House passes bill to increase debt limit, partially rescind IRS funding

May 2023

31 May - United States: Additional guidance on qualifying advanced energy project credit under section 48C(e)

31 May - Poland: New reporting requirements for cross-border payment service providers beginning 2024

31 May - Saudi Arabia: Fifth wave of e-invoicing applicability

30 May - Saudi Arabia: Annual audit certification for FATCA and CRS reporting due 1 August 2023

30 May - Dominican Republic: Updated FATCA TIN codes

30 May - Luxembourg: Parliament passes bill to implement DAC7, affecting CRS

30 May - Philippines: Optional filing and payment of monthly VAT returns for VAT-registered persons

30 May - Tanzania: Retained earnings of resident company subject to withholding tax (Tax Revenue Appeals Board decision)

30 May - UK: Definition of “structure” for capital allowance purposes (Supreme Court decision)

30 May - UK: No time limit for seeking judicial review of adverse income tax credit determination (Court of Appeal decision)

30 May - UK: Update on mandatory disclosure rules (DAC6), now effective

26 May - Nigeria: Federal Inland Revenue Service empowered to collect withholding tax as advance payment of income tax (Tax Appeal Tribunal)

26 May - Singapore: Application of GST in “direct selling” business model (High Court decision)

25 May - Germany: Expenses for rental of moveable and immoveable assets may be subject to trade tax (Federal Tax Court decision)

25 May - Germany: Losses of permanent establishments in other EU countries not deductible (Federal Tax Court decision)

25 May - Hong Kong: Voluntary e-filing of profits tax returns

25 May - India: Clarification of FATCA TIN code update

25 May - Mexico: Obligation to present tax opinion to Infonavit

25 May - United States: Guidance regarding expansion of employee plans compliance resolution system under Secure Act 2.0

25 May - United States: House Ways and Means Chairman Smith introduces bill that would impose additional tax on foreign jurisdictions with undertaxed payments rule (UTPR)

25 May - United States: IRS announces tax relief for taxpayers affected by Typhoon Mawar (Guam and Northern Mariana Islands)

24 May - United States: Finance, Ways and Means chairs and ranking members write letter to Treasury and IRS regarding Secure Act 2.0 technical corrections

24 May - United States: IRS expanding determination letter program to include certain section 403(b) plans

24 May - Bolivia: Online billing modality for “fourth group of taxpayers” postponed

24 May - EU: Update on DAC7 implementation (May 2023)

24 May - Poland: E-invoicing legislation submitted to lower house of Parliament

24 May - Poland: Excise duty on exported passenger cars not contrary to EU principles (CJEU judgment)

24 May - Poland: Insurance not subject to lump-sum income tax; scope of economic zone exemption (Supreme Administrative Court decisions)

24 May - Spain: Bill implementing DAC7; VAT, income tax, and FATCA implications for finance and insurance industries

23 May - Costa Rica: Declaration by inactive legal entities due 31 May

23 May - India: Sales tax on warranty replacements; GST on rummy; taxation of receipt of shares for inadequate consideration (court decisions)

23 May - Korea: Prices of imports and exports were not manipulated to benefit third parties (court decision)

23 May - Korea: Software installation fee is royalty subject to withholding tax under income tax treaty (Tax Tribunal decision)

22 May - British Virgin Islands: Economic substance guidance for entities claiming tax residence in Jersey, Guernsey, or Isle of Man

22 May - Egypt: Decree issued for change in income tax and VAT regulations

22 May - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on United States and UK

22 May - United States: Application of the FIRPTA regularly traded exception to stock held by partnerships (Chief Counsel legal advice memo)

22 May - United States: Domestic content bonus credit guidance under Notice 2023-38

22 May - United States: Gift tax assessment time-barred (updated with KPMG observations) (U.S. Tax Court)

22 May - United States: Interest rates, tax underpayments and overpayments remain same for third quarter 2023

22 May - United States: Minnesota (omnibus tax package); Montana (bill to exclude tax haven entities); Tennessee (tax changes enacted)

22 May - United States: Treatment of captive insurance arrangements as insurance companies for tax purposes

19 May - Australia: Updated draft practical compliance guideline on intangibles arrangements

19 May - Denmark: Beneficial ownership for purposes of withholding tax exemption for cross-border interest payments (court decision)

19 May - EU: Action seeking annulment of EU minimum tax directive (EU General Court)

19 May - EU: Agreement on DAC8 compromise text (EU Council)

19 May - France: Tax integration scheme held incompatible with EU freedom of establishment (CJEU judgment)

19 May - Saint Vincent and the Grenadines: Deadline for reporting CRS and FATCA returns is 31 May 2023

19 May - United States: Final rule implementing additional sanctions against Russia and Belarus

19 May - United States: Russia-related guidance includes general licenses, directive, determinations, and FAQs

19 May - United States: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers upheld (U.S. Supreme Court)

18 May - Singapore: Determining the true nature of payments in a transaction

18 May - South Africa: Reporting period for FATCA, CRS third-party data annual submissions process

18 May - Spain: Differential treatment runs contrary to free movement of capital for foreign, domestic non-UCITS funds (Supreme Court decision)

17 May - EU: Proposed reform of EU Customs Union

17 May - Switzerland: Transfer pricing topics of focus in audits and ruling requests

17 May - United States: BIS issues temporary denial order suspending export privileges of companies and individuals for attempts to divert electronics and aircraft parts to Russia

17 May - United States: Expenses under orphan drug credit under section 45C must also be taken in account in determining research credit under section 41 (U.S. Tax Court)

16 May - United States: Accountable care organization not entitled to tax exemption under section 501(c)(4) (U.S. Tax Court)

16 May - United States: Cost of goods sold includes only excise taxes actually paid in determining excise tax liability (U.S. Tax Court)

16 May - United States: HSA inflation-adjusted amounts for 2024

16 May - United States: IRS report on potential free e-filing system; pilot program for 2024 filing season

16 May - Channel Islands: FATCA and CRS reporting deadline is 30 June 2023 (Guernsey)

16 May - EU: New tax transparency rules for service providers facilitating cryptoasset transactions

16 May - Indonesia: Overview of transfer pricing environment

16 May - Poland: Deduction limitation applies to company’s car rental payments (Supreme Administrative Court decision)

16 May - United States: Interest expense limitations under sections 267(a)(3) and 163(j); dividend distribution with a debt

16 May - South Africa: VAT registration process becomes more stringent

15 May - South Africa: Enhancements to tax compliance status process

15 May - United States: Colorado (retail delivery fee); Florida (federal conformity, sales and use tax); Indiana (corporate income tax, sales and use tax)

15 May - United States: Taxation of paid or reimbursed travel expenses and determination of employee’s tax home

12 May - United States: USTR extension of product exclusions, China Section 301 investigation

12 May - Germany: FATCA reporting deadline is 31 July 2023

12 May - Bulgaria: No adjustment of input VAT deductions for scrapped or destroyed goods (CJEU judgment)

12 May - Cyprus: New format of tax identification number

12 May - South Africa: VAT numbers declared on customs documents monitored

12 May - UAE: New transfer pricing documentation requirements

12 May - United States: Domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E

12 May - United States: JCT overview of federal tax system (2023)

11 May - Brazil: OECD-aligned transfer pricing rules passed by Senate

11 May - Czech Republic: Sale of land treated as sale of goods for VAT purposes; no reverse charge for supplies of moveable items (Supreme Administrative Court decisions)

11 May - OECD: Public consultation on toolkits to support developing countries in addressing BEPS risks when pricing minerals

11 May - UK: Update to CRS reportable jurisdictions list

10 May - Malta: One-time concession on administrative penalties for failure to file recapitulative statements for VAT

10 May - Switzerland: Prior tax year losses allowed against real estate gains (Federal Supreme Court decision)

10 May - Poland: Council of Ministers adopt mandatory e-invoicing draft law

10 May - United States: JCT report on U.S. international taxation of U.S. multinationals, ahead of Senate Finance hearing

10 May - United States: KPMG analysis of IRS 2022 APA statistics

10 May - United States: Maryland Supreme Court dismisses challenge to digital advertising tax

10 May - United States: “Qualified research” test under section 41, summary judgment denied (U.S. Tax Court)

9 May - United States: Information reporting and transfer for valuable consideration rules for section 1035 exchanges

9 May - India: Long-term capital gains on sale of unlisted shares; attribution of profit; place of supply of intermediary services (court decisions)

9 May - Netherlands: New guidance on mandatory disclosure rules (DAC6)

9 May - Poland: Compatibility with EU law of tax exemption for real estate forming part of railway infrastructure (CJEU referral)

8 May - Mexico: Updated procedures to obtain opinion on compliance with social security tax obligations

8 May - KPMG report: Progress on improving mutual agreement procedure

8 May - United States: Third quarter update to IRS 2022-2023 Priority Guidance Plan

5 May - Romania: Tax rules for purely domestic mergers not required to be interpreted consistently with EU law (CJEU judgment)

5 May - United States: IRS provides tax relief for taxpayers in California affected by February storms

5 May - United States: Issuance of Russia-related general license, authorizing transactions related to energy

4 May - Belgium: Referral by European Commission to CJEU for failure to properly transpose CFC rules under ATAD

4 May - France: Foreign tax credit on foreign-source dividends cannot exceed corporate income tax paid on such dividends (Supreme Court decision)

4 May - Luxembourg: European Commission erred in finding grant of State aid (CJEU Advocate General opinion)

4 May - Malta: Updated FAQs with further clarifications on DAC6 notice requirements for intermediaries

4 May - Philippines: Online submission of annual tax incentives and benefits reports

4 May - Spain: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation suspended (Supreme Court decision)

4 May - United States: Request for recommendations for IRS 2023-2024 Priority Guidance Plan

3 May - United States: COVID-19 disaster relief payments under section 139

3 May - United States: IRS announces QI / WP / WT application and account management system (QAAMS) fully transitioning to new sign-in system

3 May - United States: Receipt of profits interest in partnership in exchange for services not taxable (U.S. Tax Court)

3 May - Italy: Withholding tax on dividends paid to U.S. collective investment funds breaches EU law (court decision)

2 May - Cambodia: Clarification of rules regarding when withholding tax is due

2 May - Saudi Arabia: Fourth wave of e-invoicing applicability

2 May - Singapore: FATCA and CRS return filing due 31 May 2023

2 May - United States: IRS provides tax relief for taxpayers in Florida affected by tornadoes, severe storms, and flooding

1 May - United States: Arizona (sales tax processing exemption); Michigan (delivery and installation charges subject to sales or use tax); Tennessee (excise and franchise tax changes pending enactment)

1 May - United States: IRS guidance on review and acceptance of APA submissions

1 May - UK: Business premises renovation allowances not allowed (Court of Appeal decision)

1 May - UK: Tax policy and consultation documents on modernizing, simplifying and improving the tax system

April 2023

28 Apr - Bolivia: Extended deadline for filing corporate income tax forms, statements

28 Apr - Canada: Expanded mandatory reporting obligations

28 Apr - Germany: Corporate income tax applicable to nonresident closed-end real estate funds held incompatible with EU law (CJEU judgment)

28 Apr - Spain: New reporting requirements for cross-border payment service providers beginning 2024

28 Apr - United States: IRS Commissioner Werfel testifies at House Ways and Means Committee hearing on accountability and transparency at the IRS

27 Apr - Cyprus: Update on income tax treaty with the Netherlands

27 Apr - Estonia: Date on which taxable payment from equity determined in cross-border merger of companies (Supreme Court decision)

27 Apr - Germany: Expenses for rental of trade fair stand not subject to trade tax (federal tax court decision)

27 Apr - Saint Kitts and Nevis: AEOI compliance form guidelines

26 Apr - Barbados: AEOI portal opens for 2022 submissions in May

26 Apr - India: New direct and indirect tax dispute settlement scheme (West Bengal)

26 Apr - India: Rate of dividend distribution tax may not be reduced under applicable treaty (tribunal decision)

26 Apr - Nigeria: Extended VAT filing deadline following updates to features for VAT filing and payment on online platform

26 Apr - Singapore: Digital service to view status of FATCA and CRS returns

25 Apr - France: E-invoicing and digital reporting pilot program beginning January 2024

25 Apr - United States: International tobacco company agrees to pay $508 million to settle violations of sanctions against North Korea and weapons of mass destruction proliferators

25 Apr - Colombia: Updated electronic invoicing regulations

25 Apr - Peru: Updates to CRS reporting deadlines

25 Apr - Thailand: Draft legislation requiring automatic exchange of information (AEOI)

25 Apr - Uruguay: Updated CRS submission details

24 Apr - Cyprus: Extension of deadline for VAT returns

24 Apr - India: Amnesty program for non-compliance of export obligations

24 Apr - India: Determination of arm’s length prices by Tribunal subject to review by High Courts (Supreme Court decision)

24 Apr - Korea: Criteria for selection of comparable companies (Tax Tribunal decision)

24 Apr - Korea: Customs penalty upheld even though taxpayer voluntarily amended customs value (Tax Tribunal decision)

24 Apr - Nigeria: Guidelines on process of generating electronic tax clearance certificate (Lagos State)

24 Apr - Nigeria: Updated features for VAT filing and payment on online platform

24 Apr - United States: Effect of IRS funding on information reporting

24 Apr - United States: Colorado (effect of CARES Act); Missouri (sales and use tax manufacturing exemption); Virginia (federal conformity)

24 Apr - United States: IRS provides tax relief for taxpayers in Oklahoma affected by storms, straight-line winds, and tornadoes

21 Apr - Thailand: Requirements for e-tax invoice

20 Apr - Canada: Extension of manufacturing and processing exporter tax incentive (Saskatchewan)

20 Apr - EU: European Commission adopts DAC7 for exchange of information with non-EU countries

20 Apr - EU: European Economic and Social Committee adopts supportive opinion on DAC8 proposal

20 Apr - Finland: Instructions for missing U.S. TINs for FATCA purposes

20 Apr - India: Withdrawal of GST exemption for passenger transportation services booked through electronic platform upheld (high court decision)

20 Apr - Italy: Draft legislation for implementation of DAC7

20 Apr - Lithuania: Draft legislation implementing public country-by-country reporting

20 Apr - Nigeria: State infrastructure maintenance and development levies enforced (Tax Appeal Tribunal decision)

20 Apr - Spain: Withholding tax on royalties must be on net basis (court decision)

20 Apr - United States: Annuity payments received from charitable remainder trusts taxable as ordinary income (U.S. Tax Court)

20 Apr - United States: Foreign insurance companies; effectively connected net investment income (2022)

19 Apr - United States: IRS Commissioner Werfel testifies at Senate Finance Committee hearing on 2024 IRS budget and IRS’s 2023 filing season

19 Apr - United States: Technology export controls for automated peptide synthesizers

19 Apr - Mongolia: Commitment to start automatic exchange of information (AEOI) by 2026

18 Apr - Spain: Constitutional challenge to temporary solidarity tax on large fortunes

18 Apr - Mexico: Increase in lodging tax rate for certain tourist accommodation services (State of Guerrero)

18 Apr - United States: JCT report on energy-related tax changes made by “Inflation Reduction Act of 2022”

18 Apr - United States: IRS provides tax relief for taxpayers in Indiana affected by tornadoes and severe storms

18 Apr - United States: Order renewing—for a second time—temporary denial of export privileges of Russian airline

17 Apr - United States: Arkansas (corporate rate reduction, throwback rule phase out); Kentucky (definition of telemarketing services); Washington State (B&O deduction for investment income)

17 Apr - EU: WTO case on India’s tariffs on information and communication technology products

17 Apr - Poland: Dividends paid to foreign related entity subject to withholding tax (court decision)

17 Apr - Saudi Arabia: Amendments to transfer pricing bylaws

14 Apr - Luxembourg: Draft legislation on APAs and MAP procedures, transfer pricing documentation requirements, and general tax procedures

14 Apr - Czech Republic: Compensation paid to electricity and gas suppliers subject to VAT

14 Apr - Czech Republic: Deductibility of advertising costs (Supreme Administrative Court decisions)

14 Apr - Czech Republic: Updated information on tax assessment obligations of accommodation service providers

14 Apr - United States: IRS releases tax collection data for fiscal year 2022

14 Apr - United States: Safe harbor method of accounting for expenses related to natural gas transmission and distribution property

13 Apr - Cayman Islands: Updated FATCA and CRS deadlines

13 Apr - Philippines: Online registration and update system introduced

13 Apr - United States: Initial observations on Notice 2023-29 guidance on determining energy communities for IRA tax credits

12 Apr - United States: Prior ruling relating to expensing of research and experimentation expenditures obsolete

12 Apr - United States: Additions and revisions to Export Administration Regulations (EAR) entity list

12 Apr - KPMG report: Transfer pricing and ESG—public tax strategies and tax transparency

12 Apr - Poland: Limit on deductibility for costs of intangible services; deductibility of expenses relating to opening event (Supreme Administrative Court decisions)

12 Apr - Poland: New binding rate information template

12 Apr - South Africa: Additional disclosure requirements for trusts

11 Apr - Australia: Draft legislation for public country-by-country (CbC) reporting

11 Apr - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for March 2023

11 Apr - United States: Expansion of defense articles and services eligible for transfer under Canadian and treaty exemptions

10 Apr - United States: Colorado (notice of tax credits to employees); Georgia (federal tax conformity); New Mexico (tax package vetoed); West Virginia (apportionment changes)

10 Apr - United States: IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms

10 Apr - United States: Rules for supervisory approval of penalties

7 Apr - United States: Revised Form 3115 for applications for change in accounting method

7 Apr - Saudi Arabia: Third wave of e-invoicing applicability

7 Apr - United States: No change to list of countries cooperating with international boycott

6 Apr - Bahamas: Economic substance legislation and guidance notes introduced

6 Apr - Canada: Reminder of 30 April 2023 deadline, tax on cross-border insurance

6 Apr - Switzerland: Reminder of 30 June 2023 deadline to claim VAT refunds

6 Apr - United States: IRS releases strategic operating plan for use of IRA funds

5 Apr - United States: Foreign taxes paid on accumulated earnings offset under section 965 are creditable (federal district court)

5 Apr - Estonia: Guidance on tax defensive measures relating to non-cooperative jurisdictions

5 Apr - Honduras: FATCA reporting deadline extended to 30 April 2023

5 Apr - India: Fees for technical services and royalties under treaties; grounds for denying refund (court decisions)

4 Apr - Bolivia: Modernization of registration procedures and modification to national digital biometric taxpayer register

4 Apr - EU: Updated State aid guiding templates

4 Apr - Mexico: Payroll electronic invoice 4.0 (CFDI 4.0) mandatory beginning 1 July 2023 (three-month extension)

4 Apr - Philippines: Guidance on return processing system assessment notices

4 Apr - Poland: Deductibility of interest on late payments; depreciation by real estate companies (court decisions)

4 Apr - Poland: Municipality installing renewable energy systems and removing asbestos not subject to VAT (CJEU judgment)

4 Apr - Spain: Updated FATCA FAQs concerning U.S. TINs

4 Apr - United States: Guidance on requirements for energy community production and investment tax credits under IRA

3 Apr - United States: Extension of transition period for single-country exception documentation requirement under section 903

3 Apr - United States: IRS lacks statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471 (U.S. Tax Court)

3 Apr - United States: IRS provides tax relief for taxpayers in Arkansas affected by tornadoes and severe storms

3 Apr - United States: Kentucky (sales and use tax); Mississippi (changes related to section 174); Mississippi (sales tax treatment of computer software); Washington State (capital gains tax is permissible excise tax)

3 Apr - Bahrain: Penalties applied to unregistered businesses charging VAT on supplies

3 Apr - UK: Mandatory disclosure rules (DAC6) effective

March 2023

31 Mar - Brazil: OECD-aligned transfer pricing rules passed by Chamber of Deputies, await vote in Senate

31 Mar - Canada: Penalty, interest relief for late-filed underused housing tax returns

31 Mar - United States: Guidance on new clean vehicle credit

30 Mar - Serbia: Rulebook on arm’s length interest rates for 2023

30 Mar - Spain: Services performed by Spanish branch for foreign head office not subject to VAT (National High Court decision)

30 Mar - Sweden: Foreign tax credit carryforward allowed on income not subject to foreign tax

30 Mar - United States: OFAC issues amended Russia-related FAQ, “exit tax” payment prior to divestment of assets located in Russia

29 Mar - United States: APMA program, APA statistics for 2022

29 Mar - United States: No basis step-up for assets of irrevocable grantor trust not included in grantor’s estate

29 Mar - Poland: Deadline for corporate income tax filings extended to 30 June 2023

29 Mar - Poland: Limitation period for tax liabilities (COVID-19); R&D costs; real estate tax (Supreme Administrative Court decisions)

29 Mar -  South Africa: New dispute resolution rules

29 Mar - Germany: Shareholder not entitled to challenge assessment against corporation (federal tax court decision)

28 Mar - Germany: Taxation of profits from cryptocurrencies (federal tax court decision)

28 Mar - Poland: New bill on mandatory use of national e-invoicing system

28 Mar - United States: IRS provides tax relief for taxpayers in Mississippi affected by tornadoes and severe storms

27 Mar - Sweden: Draft legislation implementing public country-by-country reporting presented to parliament

27 Mar - Switzerland: New goods traffic system for digital processing of customs procedures

27 Mar - UK: Parliament passes Australia-UK free trade agreement legislation

27 Mar - United States: Clarification of date on which substances added or removed from Superfund list

27 Mar - United States: IRS guidance on electronic filing of Form 8038-CP for bond issuers requesting tax credit payments

27 Mar - United States: Superfund excise taxes, extension of relief regarding failure to deposit penalties

24 Mar - United States: IRS provides tax relief for taxpayers in New York affected by winter storms, snowstorms

24 Mar - United States: Beneficial ownership information reporting guidance

24 Mar - United States: Rule amending Belarus Sanctions Regulations

23 Mar - United States: Revisions to “unverified list”

23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax

23 Mar - Greece: Updated lists of non-cooperative jurisdictions and preferential tax regime countries

23 Mar - Malta: Clarifications on DAC6 notification requirements for intermediaries

22 Mar - Bahrain: Mandatory digital stamps for waterpipe tobacco products

22 Mar - Belgium: Draft legislation modernizing “VAT chain” passed by Chamber of Representatives

22 Mar - Bolivia: Online billing modality for “fourth group of taxpayers”

22 Mar - Spain: Public consultation on Pillar Two global minimum tax

22 Mar - United States: IRS provides revised FAQs on Form 1099-K

21 Mar - United States: Guidance and request for comments on treatment of certain NFTs as section 408(m) collectibles

21 Mar - Australia: Draft legislation requiring disclosure of subsidiaries' tax residence in financial reports

21 Mar - Chile: Tax treatment of expenses and donations associated with catastrophes; VAT development

21 Mar - Montenegro: Amendments to tax law include changes to Local file requirements

21 Mar - Qatar: Income tax treaty signed with Egypt

20 Mar - India: Proof required for claiming input VAT credit (Supreme Court decision)

20 Mar - Korea: Tax authority entitled to re-assess arm’s length interest rate on related-party loan (Tax Tribunal decision)

20 Mar - Korea: Advance customs valuation arrangement, coordination with transfer pricing

20 Mar - UK:  Group relief provision compatible with EU law (Court of Appeal judgment)

20 Mar - United States: California (unclaimed property); Colorado (real estate sales and receipts factor); Florida (costs of performance sourcing rule); Louisiana (sales and use tax informational report); Montana (single receipts factor)

17 Mar - United States: Charitable deduction denied, donor must realize capital gains shares sold by donee (U.S. Tax Court)

17 Mar - United States: IRS provides tax relief for taxpayers in California affected by March storms, flooding, landslides, mudslides

17 Mar - United States: IRS TE/GE division provides two new technical guides

17 Mar - United States: USTR adequately responded to remand in case challenging tariffs on imports from China (U.S. trade court)

17 Mar - Cyprus: Mandatory use of single tax portal for VAT payments

17 Mar - Indonesia: New customs and VAT obligations on imported software products, other digital goods

17 Mar - Mexico: Figure of “compensation” not a payment of VAT (court decision)

17 Mar - United States: Crypto crackdown—information reporting in a digital asset world

17 Mar - United States: FASB proposed accounting standards update addresses requests for improved tax disclosures

17 Mar - United States: IRS provides FAQs on whether nutrition, wellness, and general health costs are medical expenses

16 Mar - OECD: Public consultation meeting on implementation under Pillar Two

15 Mar - Poland: Extended deadline for submitting ORD-U reports

15 Mar - Poland: Scope of debt financing expenses; taxation of cross-border employee (Supreme Administrative Court decisions)

15 Mar - United States: Guidance concerning unclaimed property voluntary compliance program (California)

15 Mar - United States: ITC report on implication of sections 232 and 301 tariffs on imports

15 Mar - United States: Notice of filing of petition for addition of cellulose acetate (degree of substitution = 1.5 – 2.0) to Superfund list

14 Mar - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2024 budget

14 Mar - Channel Islands: Guidance on updates to U.S. TIN reporting obligations (Guernsey)

14 Mar - India: Transfer pricing rules apply if counterparty becomes associated enterprise in same tax year (tribunal decision)

14 Mar - United States: Housing expense limit adjustments, foreign locations for 2023

14 Mar - United States: Proposed regulations concerning Superfund chemical tax and Superfund imported substance tax; OIRA review completed

13 Mar - Czech Republic: Ownership of goods for VAT purposes (Supreme Administrative Court decision)

13 Mar - India: Salaries of seconded employees; extension of time for reassessment notices; tax residency certificates (court decisions)

13 Mar - Nigeria: Joint tax audit and investigation team (Lagos State)

13 Mar - Saudi Arabia: Public consultation on draft amendments to Zakat implementing regulations

13 Mar - United States: Minnesota (sales tax guidance for marketplace providers); Texas (apportionment for franchise tax); Wisconsin (online ticket marketplace liable for sales and use tax)

13 Mar - United States: Waiver for individuals electing to exclude foreign earned income

13 Mar - United States: Werfel sworn in as new IRS Commissioner

10 Mar - United States: IRS acquiescence to Fifth Circuit decision, tax on exports of domestic crude oil held unconstitutional

10 Mar - United States: Tax return not considered filed when sent in response to IRS inquiry; Tax Court affirmed (Ninth Circuit)

10 Mar - Cyprus: Frequently asked questions on transfer pricing documentation rules

10 Mar - Czech Republic: Updated list of non-cooperative jurisdictions

10 Mar - France: Ruling on withholding tax on dividend equivalent payments

10 Mar - Kenya: VAT on exported services is standard rated at 16% (court decision)

10 Mar - Luxembourg: Draft legislation for implementation of public country-by-country reporting

10 Mar - Mauritius: Disclosure of U.S. TINs in FATCA returns

10 Mar - Netherlands: Ruling on permanent establishment issues when employees work from home

9 Mar - Malta: Updated automatic exchange of information (AEOI) implementing guidelines

9 Mar - South Africa: Ten-year extension of R&D tax incentive announced

9 Mar - United States: Credit for production of electricity from advanced nuclear power facilities under section 45J

9 Mar - United States: FY 2024 budget: “Green Book”—Treasury’s explanation of tax proposals

9 Mar - United States: Indexing adjustments for amounts used to calculate employer shared responsibility payments

9 Mar - United States: Senate confirms Werfel to be IRS Commissioner

8 Mar - KPMG report: Transfer pricing implications of intercompany fees for internal carbon pricing

8 Mar - Canada: Rephrased source of income test (court decision)

8 Mar - Mexico: Extension for submission of informative returns

8 Mar - Netherlands: Deduction of interest not limited in active group financing companies (Supreme Court decision)

8 Mar - Vietnam: Directives on tax inspections and tax audits for 2023

7 Mar - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for February 2023

7 Mar - Poland: Public consultation on transfer pricing cost-plus method regulations

7 Mar - Poland: Tax-deductible costs in revenue and expense ledgers; mutual trademark transactions

7 Mar - United States: Relief for reporting required minimum distributions for 2023

7 Mar - United States: Research tax credit disallowed, Tax Court affirmed

6 Mar - United States: District of Columbia (sales tax on resold items); multistate (escheatment of abandoned property); multistate (corporate surtaxes)

6 Mar - Cyprus: Extension of time for objecting to tax assessment notices

6 Mar - Hong Kong: Instrument of ratification of MLI deposited with OECD

3 Mar - Poland: Obligation to disclose interests in real estate companies applies to non-residents

2 Mar - United States: Finance Committee advances Werfel to be next IRS Commissioner

1 Mar - Germany: Reduction of the basis for assessment of VAT due to irrecoverable debts, other VAT developments

1 Mar - KPMG report: Recent U.S. Trade Court decision on customs “origin”

February 2023

28 Feb - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU judgment)

28 Feb - United States: IRS reminder of 1 March deadline for farmers or fishers not making quarterly estimated tax payments

28 Feb - United States: Penalty for FBAR violation applies on per-report, not per-account basis (U.S. Supreme Court)

27 Feb - Brazil: Guidance on new OECD-aligned transfer pricing rules

27 Feb - Germany: Summary of recent federal tax court decisions

27 Feb - Italy: Withholding tax on dividends paid to investment fund breaches EU law (court decision)

27 Feb - Poland: Scope of tax rulings; due diligence obligation of tax remitters (Supreme Administrative Court decisions)

27 Feb - Poland: VAT exclusion for supply of undertaking or organized part thereof (CJEU judgment)

27 Feb - United States: Corporate Alternative Minimum Tax considerations and FAQs (updated after Notices 2023-7 and 2023-20)

27 Feb - United States: Electronic-filing requirements for exempt organization returns, other returns and documents

27 Feb - United States: Mississippi (decoupling from section 174); Pennsylvania (income-producing activity test); Washington State (capital gains excise tax); multistate (federal tax conformity)

27 Feb - United States: Relief with respect to lookback periods for returns with postponed due dates

24 Feb - United States: IRS provides tax relief for “disaster area taxpayers” in Alabama, California, Georgia

24 Feb - Belgium: Qualitative evaluation of whether renovations constitute new construction for VAT purposes required (court decision)

24 Feb - Channel Islands: No change in deadline for FATCA and CRS reporting (Guernsey)

24 Feb - Malta: Electronic filing of VAT returns and payments due 22 February 2023 extended to 28 February 2023

24 Feb - Malta: One-year extension of allowance to transfer unabsorbed capital allowances intra-group

24 Feb - United States: Guidance on Section 301 duties and product exclusions (imports from China)

24 Feb - United States: Proposed regulations concerning information returns of cryptocurrency brokers; OIRA review completed

23 Feb - United States: Final versions of Form 5500 series, annual employee benefit plan reports

23 Feb - United States: “Benefits-received” interpretation of income-producing activity test upheld (Supreme Court decision)

23 Feb - Mexico: Rules for issuance of tax compliance opinion (Nuevo Leon)

23 Feb - Philippines: Letter of authority required to vest authority in new revenue officer (Supreme Court resolution)

23 Feb - UK: Group transfer rules not contrary to EU law (CJEU judgment)

22 Feb - Australia: Updated U.S. TIN codes for FATCA purposes

22 Feb - South Africa: Guidance providing clarification for FATCA reporting TIN codes

21 Feb - Denmark: New automatic check of reported VAT figures

21 Feb - Mexico: Agreement to facilitate payroll tax withholding (Nuevo Leon)

21 Feb - Poland: Definition of “joint venture”; deductibility of employment contract termination costs (court decisions)

21 Feb - Poland: Draft decree would extend deadline for 2022 corporate income tax returns to 30 June 2023

21 Feb - Spain: Publication of list of non-cooperative jurisdictions

21 Feb - United States: Electronic-filing requirements for specific tax returns, other documents

21 Feb - United States: Observations from Notice 2023-20 (guidance regarding certain insurance related issues under corporate alternative minimum tax)

20 Feb - United States: California (unclaimed brokerage accounts); Louisiana (cloud-based storage plans not subject to sales tax); Louisiana (manufacturing machinery and equipment sales tax exclusion); Tennessee (deduction for FDII)

20 Feb - United States: Observations from Notice 2023-18 (guidance on qualifying advanced energy project credit under section 48C)

20 Feb - Korea: Customs and VAT valuation of “free samples” provided under supply contract (Supreme Court decision)

20 Feb - Korea: Tax authority not entitled to select only certain local distributors for transfer pricing adjustment (Tax Tribunal decision)

20 Feb - Nigeria: Network facilities providers not subject to National Information Technology Development Agency (NITDA) levy (Tax Appeal Tribunal decision)

20 Feb - UK: Guidance under new mandatory disclosure rules

20 Feb - UK: Overview of employer-financed retirement benefit schemes and related compliance obligations

17 Feb - United States: Interim guidance regarding certain insurance related issues under corporate alternative minimum tax (CAMT)

16 Feb - Brazil: Changes in tax disputes resolution system

16 Feb - India: Vouchers not subject to GST; “risky exporter” entitled to GST refund; dismissal held improper (court decisions)

16 Feb - OECD: Comments on public consultation documents on implementation under Pillar Two

15 Feb - OECD: New toolkit to strengthen effective collection of VAT on e-commerce in Africa

15 Feb - Armenia: Commitment to start automatic exchange of information (AEOI) by 2025

15 Feb - Ireland: Summaries of FATCA and CRS reporting requirements

15 Feb - UK: HMRC transfer pricing and diverted profits tax statistics for year ended 31 March 2022

14 Feb - United States: Link for renewal of QI agreements now live

14 Feb - Czech Republic: Abuse of law concept, documentation of expenses for related-party services (regional court decisions)

14 Feb - EU: Updates to list of non-cooperative jurisdictions (four added to “black list”, revisions to “grey list”)

14 Feb - Ghana: Mandatory online filing of individual income tax returns

14 Feb - KPMG report: Changes to Brazilian transfer pricing and royalty deduction rules, implications for U.S. multinationals

14 Feb - Poland: Draft legislation implementing new reporting obligations for digital platform operators (DAC7)

14 Feb - Poland: Extended deadline for 2022 corporate income tax returns

13 Feb - United States: IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program

13 Feb - United States: IRS guidance on state tax refunds, general welfare and disaster relief payments

13 Feb - United States: Guidance on environmental justice solar and wind capacity limitation under section 48(e)

13 Feb - United States: Guidance on qualifying advanced energy project credit under section 48C

13 Feb - United States: Interest rates, tax underpayments and overpayments remain same for second quarter 2023

13 Feb - United States: Minnesota (retail delivery fee); Missouri (resale tax exemption); multistate (taxation of digital products and services and software)

13 Feb - Sweden: Proposal for implementation of public country-by-country reporting

10 Feb - Finland: Updated FATCA reporting requirements

9 Feb - Bolivia: Extended deadline for certain taxpayers to register in purchases and sales registry

9 Feb - Canada: Prescribed rates of interest for income tax, PLOI purposes (second quarter 2023)

9 Feb - India: Tax residency certificate sufficient evidence of residency under India-Singapore income tax treaty (high court decision)

9 Feb - KPMG report: Administrative guidance on the GloBE rules, focusing on issues of importance to U.S. companies

9 Feb - UK: Updated FATCA reporting guidance

9 Feb - United States: Regulation under section 482 relating to consideration of foreign legal restrictions upheld (U.S. Tax Court)

8 Feb - Mauritius: Taxation of variable capital companies

8 Feb - United States: Updates on third six-year remedial amendment cycle for pre-approved defined benefit plans

7 Feb - Canada: New underused housing tax (UHT) filing, payment due 30 April

7 Feb - EU: Access to documents of EU Council working groups on public country-by-country reporting (EU General Court)

7 Feb - Romania: New reporting obligations for digital platform operators (DAC7)

7 Feb - United States: Gain recognized on sale of partnership interest attributable to inventory may be U.S.-source income (U.S. Tax Court)

6 Feb - United States: Arizona (transaction privilege tax); Michigan (rolling stock use tax exemption); Texas (sourcing of local sales tax on internet orders); Wisconsin (nonconformity with section 174 changes)

6 Feb - United States: Guidance on implementation of Russia-origin petroleum products price cap policy

6 Feb - Poland: Guidance for real estate companies, deductibility of intangible services costs incurred by acquired subsidiary (court decisions)

6 Feb - Poland: VAT rate ambiguities interpreted in taxpayers’ favor; “Slim VAT 4 package” announced

6 Feb - Qatar: Amendment of transfer pricing-related provisions of Income Tax Law for 2018

6 Feb - Switzerland: Overview and case study of administrative assistance procedure under income tax treaties

3 Feb - Argentina: Guidance for taxpayers to mitigate freely available balances in income tax collection regime

3 Feb - Bolivia: Extended deadline for online billing modality, Form 510 submission and payment

3 Feb - Netherlands: Interest on corporate income tax and withholding tax to increase to 10.5%

3 Feb - United States: IRS updates FAQs on QI / WP / WT website, certifications and periodic reviews

3 Feb - United States: Service industry tip compliance agreement program

3 Feb - United States: Updated FAQs for clean vehicle credit under section 30D

2 Feb - OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules

2 Feb - Poland: Mandatory e-invoicing postponed until 1 July 2024

2 Feb - Spain: State aid determination annulled because aid recipients were erroneously identified (CJEU judgment)

1 Feb - Malta: Updated automatic exchange of information (AEOI) implementing guidelines

1 Feb - Nigeria: Federal Inland Revenue Service only authority for assessment and collection of taxes (court decision)

1 Feb - OECD: Manual on handling of mutual agreement procedures (MAPs) and advance pricing arrangements (APAs)

January 2023

31 Jan - Estonia: Company board member not liable for company’s VAT and income tax liabilities (Supreme Court decision)

31 Jan - Estonia: Country-by-country reporting and transfer pricing documentation deadlines

31 Jan - Ghana: Inauguration of Independent Tax Appeals Board

31 Jan - Serbia: New practice regarding collection of tax

30 Jan - Australia: Updated 2023 U.S. TIN reporting requirements under FATCA regime

30 Jan - Denmark: Beneficial ownership for purposes of withholding on dividends (Supreme Court decisions)

30 Jan - EU: European Commission public consultation on DAC7 implementing regulation

30 Jan - EU: Report on “Unshell” Directive proposal adopted by EU Parliament

30 Jan - Germany: Dividends received by partnership not eligible for exemption under EU Parent-Subsidiary Directive (tax court decision)

30 Jan - Germany: Taxpayer satisfied “motive test“ under CFC rules (lower tax court decision)

30 Jan - OECD: Comments on public consultation document on Amount B under Pillar One

30 Jan - Poland: Timing of income recognition with respect to overpaid taxes, income recognition from social security contributions (Supreme Administrative Court decisions)

30 Jan - Romania: Withholding tax on renumeration paid to non-resident service provider (CJEU Advocate General opinion)

30 Jan - Spain: Public consultation on changes to criteria for non-cooperative jurisdictions

30 Jan - United States: Illinois (amended return was timely filed); Texas (taxpayer may not amend franchise tax report); multistate (combined reporting)

27 Jan - United States: New rules and conditions for implementing alternative cost method for real estate developers

27 Jan - KPMG report: Comments on public consultation on new common corporate tax system in the EU (BEFIT)

27 Jan - Sweden: Penalties for omission of Form N9 relating to negative net interest income (Court of Appeal decisions)

26 Jan - United States: IRS annual revenue procedures for 2023

26 Jan - United States: Updated Technical Guide, excise taxes on self-dealing under section 4941

25 Jan - Cambodia: E-documents facility no longer available for monthly and annual tax on income declarations

25 Jan - KPMG report: Comments on public consultation document on Amount B under Pillar One

25 Jan - Netherlands: Guidance on rule to combat transfer pricing mismatches in context of capital contributions

25 Jan - Poland: Guidance on partnership merger, transformation (Supreme Administrative Court decisions)

24 Jan - United States: IRS provides tax relief for taxpayers in California affected by December storms, flooding, mudslides

24 Jan - Nigeria: Deadline for employer’s filing PAYE tax returns is 31 January 2023

24 Jan - OECD: New methodology for Action 14 peer reviews, changes to MAP statistics reporting and new APA statistics reporting

24 Jan - Philippines: Guidance concerning submission of inventory list and application of VAT to HMO plans of registered export enterprises

24 Jan - Poland: Deadline for follow-up withholding tax statement is 31 January 2023

24 Jan - United States: Form 1099-K delayed reporting thresholds

24 Jan - United States: State and local tax, technology-related developments (table, fourth quarter 2022)

23 Jan - Channel Islands: FATCA and CRS compliance program for 2023 (Jersey)

23 Jan - Finland: Reminder of FATCA and CRS annual information return submission deadlines

23 Jan - Hungary: Changes to transfer pricing rules, including reporting and documentation

23 Jan - KPMG report: Focus on country-by-country reporting (CbC) data with Pillar Two minimum tax and public CbC reporting

23 Jan - UK: Consultation on R&D tax relief reform

23 Jan - UK: Elements of nuclear decommissioning facility qualifying for plant and machinery allowances (Court of Appeal decision)

23 Jan - UK: Final mandatory disclosure rules (DAC6) regulations published

23 Jan - United States: Florida (sales tax refunds on software and hardware); Texas (margin tax apportionment); Virginia (NOL carryback)

20 Jan - United States: IRS extends due date for QI withholding agreement to 1 May 2023

20 Jan - United States: Permanent injunction against “tax mandate” in American Rescue Plan Act upheld (Eleventh Circuit)

20 Jan - Korea: Royalties subject to withholding under Korea-U.S. treaty (tax tribunal decision)

20 Jan - Mexico: Single self-determination system version 3.6.3

20 Jan - Uganda: Requirement to submit beneficial owners’ information

19 Jan - Cyprus: New single tax administration portal

19 Jan - Poland: Guidance on tax rulings (Supreme Administrative Court decisions)

19 Jan - South Africa: Interpretation note providing transfer pricing guidance on intragroup loans

19 Jan - United States: IRS provides tax relief for taxpayers in Georgia and Alabama affected by storms

18 Jan - United States: Changes in accounting methods (IRS practice units)

18 Jan - United States: Employers must file Forms W-2 and provide Forms 1099-NEC by 31 January 2023 (IRS reminder)

18 Jan - United States: Minnesota (federal tax conformity); Missouri (sales and use tax changes); Ohio (tax and fee amnesty); Washington State (bad debt sales tax credit and B&O tax deduction)

18 Jan - United States: SEC comments on accounting for income taxes

18 Jan - Botswana: Reduced VAT rate extended through 31 March 2023

18 Jan - Channel Islands: Annual tax reporting for partnerships (Jersey)

18 Jan - India: Exemption rule for educational institutions applies prospectively; beneficial owner of fees for technical services (court decisions)

17 Jan - United States: Export controls of certain advanced computing and semiconductor manufacturing items extended to Macau

17 Jan - Czech Republic: Application of thin capitalization test to interest paid on bonds (court decision)

17 Jan - Czech Republic: Guidance provided in Q&As on new reporting obligation under DAC7

17 Jan - Czech Republic: Referral to CJEU of issue relating to VAT exemption for supplies of goods to another member state when recipient is unknown

17 Jan - Greece: Instructions on procedure for adjustment of taxable profits following tax audit

17 Jan - India: Liaison office did not constitute PE; amalgamation plan rejected (court decisions)

17 Jan - Philippines: Monthly VAT declaration no longer required

13 Jan - Japan: FAQs on AEOI process for non-residents

13 Jan - Japan: Updated FAQs on AEOI reporting system under CRS regime

13 Jan - OECD: Manal Corwin appointed new Director of its Centre for Tax Policy and Administration

13 Jan - Slovakia: Changes to content of transfer pricing documentation

13 Jan - South Africa: Change in VAT treatment of “scrip-lending transactions”

13 Jan - United States: Amendments to EAR; controls on marine toxins, plant pathogens, biological equipment

12 Jan - United States: Annual inflation adjustment to civil monetary penalties

12 Jan - United States: Tax season starts 23 January 2023; most individual returns due 18 April 2023

12 Jan - Panama: Deadline for submitting 2021 country-by-country reports extended to 15 January 2023

11 Jan - EU: Update on DAC7 implementation

11 Jan - India: Withholding not required on estimated payments; application of beneficial treaty rate upheld (High Court decisions)

11 Jan - Poland: Changes to enforcement proceedings include recovery of VAT

11 Jan - Poland: Recent tax-related developments (court decisions)

11 Jan - Spain: Public country-by-country reporting implemented

11 Jan - Sweden: License fees paid to companies not performing DEMPE functions are not deductible (court decision)

11 Jan - United States: National Taxpayer Advocate report to Congress identifying taxpayer challenges, describing better outlook for 2023

10 Jan - United States: IRS provides tax relief for taxpayers in California affected by storms, flooding, mudslides

10 Jan - Bulgaria: Changes in VAT law, including reporting of data regarding cross-border payments

10 Jan - Kosovo: Introduction of tax procedures for application of income tax treaties

10 Jan - North Macedonia: Proposed changes to transfer pricing reporting

10 Jan - Singapore: Cement silo is not a “plant” for capital allowance purposes (court decision)

10 Jan - United States: House passes IRS defunding bill

10 Jan - United States: Jason Smith selected to chair House Ways and Means Committee

9 Jan - Canada: Importers subject to increased scrutiny regarding goods in supply chain

9 Jan - Panama: Period for satisfying some tax obligations is extended to 13 January 2023

9 Jan - UK: New guidance on “associated companies” test for determining applicable corporation tax rate and payment deadlines

9 Jan - UK: New transfer pricing documentation requirements, but delay of summary audit trail (SAT) pending public consultation

9 Jan - UK: “Time to pay” arrangements to help mitigate liquidity challenges

5 Jan - Germany: Updated CRS guidance

3 Jan - Poland: Corporate income tax exemption applied to total revenue from activities performed in special economic zones (court decision)

3 Jan - Montenegro: Arm’s length interest rate for 2023

3 Jan - Poland: Interest rates for transfer pricing purposes

3 Jan - Saudi Arabia: Second wave of e-invoicing applicability

3 Jan - Saudi Arabia: Zakat rules for investments in investment funds

1 Jan - United States: Analysis and observations on Rev. Procs. 2023-8 and 2023-11, guidance for accounting method changes under section 174

2022 Articles

December 2022

30 Dec - United States: Deadline for renewal of QI agreements covering 2023 through 2028

30 Dec - United States: IRS provides tax relief for taxpayers in New York affected by winter storm

30 Dec - United States: Notice of filing of petition for addition of polyphenylene sulfide to Superfund list

30 Dec - United States: Temporary relief for foreign financial institutions required to report U.S. TINs

29 Dec - Brazil: Draft legislation to align transfer pricing rules with OECD Transfer Pricing Guidelines

29 Dec - United States: Intention to propose regulations on requirements of clean vehicle credit under section 30D

29 Dec - United States: IRS provides FAQs on clean vehicle credits for new, previously owned and commercial vehicles

29 Dec - United States: Proposed regulations concerning electronically filed returns; OIRA review completed

29 Dec - United States: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

29 Dec - United States: Standard mileage rates for 2023

29 Dec - United States: Treasury releases white paper on critical mineral and battery component requirements for clean vehicle tax credits

29 Dec - United States: Updated guidelines for accounting method changes for specified R&E expenditures

28 Dec - United States: IRS provides updated FAQs on Form 1099-K

27 Dec - United States: Interim guidance on new 1% excise tax on repurchases of corporate stock

27 Dec - United States: Interim guidance on new corporate alternative minimum tax (CAMT)

23 Dec - United States: Delay of implementation of $600 reporting threshold for Forms 1099-K

23 Dec - United States: Insurance companies, unpaid loss discount factors for 2022 accident year

23 Dec - United States: Transitional guidance for broker reporting on digital assets

22 Dec - Italy: Obligation to report information and withhold tax on short-term rentals upheld (CJEU judgment)

22 Dec - KPMG report: Public consultation document under Pillar One on draft multilateral convention provisions on DSTs

22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)

22 Dec - Latvia: Penalty for non-compliant transfer pricing documentation

22 Dec - Morocco: Temporary suspension of country-by-country report local filing requirement

22 Dec - Netherlands: 2023 Tax Plan adopted by upper house of Parliament, including DAC7, windfall profits tax on fossil sector

22 Dec - United States: IRS provides FAQs on energy efficient home improvements and residential clean energy property credits

22 Dec - United States: Senate passes Consolidated Appropriations Act (with revenue provisions)

21 Dec - United States: Guidance regarding withholding on transfers of publicly traded partnership interests

21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis

21 Dec - Serbia: Changes to tax procedure and administration law

20 Dec - Canada: Updated FATCA and CRS self-certification forms

20 Dec - Hong Kong: Upfront lump-sum spectrum license fees must be capitalized (court decision)

20 Dec - OECD: Public consultation documents on withdrawal of DSTs under Pillar One, implementation under Pillar Two

20 Dec - Philippines: Temporary suspension of field audits and operations

20 Dec - UAE: New transfer pricing rules

19 Dec - Serbia: Rulebook on arm’s length interest rates for 2022

19 Dec - UK: HMRC guidance on redaction of information under AEOI on human rights ground

19 Dec - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Nicole

19 Dec - United States: Treasury timeline for providing guidance on “Inflation Reduction Act” tax provisions

16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax

16 Dec - EU: Council adopts EU minimum tax directive

16 Dec - Belgium: New obligations of digital platform operators (DAC7)

16 Dec - Korea: Tax authority’s determination of arm’s length price upheld (Tax Tribunal decision)

15 Dec - Korea: Liquidated damages for non-fulfillment of minimum purchase quantity included in price of imported goods

15 Dec - Hungary: Guidance on transfer pricing reporting

15 Dec - Mexico: Limitation on deductibility of net interest held valid (court decision)

15 Dec - Saudi Arabia: Penalty waiver for all taxes, including VAT and excise tax extended until May 2023

14 Dec - EU: Proposal to extend tax transparency rules to cryptoassets

14 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5

13 Dec - Poland: Application of general anti-avoidance clause (GAAR)

13 Dec - Czech Republic: Taxpayer entitled to deduct VAT on supply within fraudulent transactions chain (Supreme Administrative Court decision)

13 Dec - Czech Republic: Tax loss from transfer pricing adjustments abroad denied (court decision)

13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)

13 Dec - EU: VAT gap statistics for 2020

13 Dec - India: Set-off of loss against foreign dividend income; revaluation of partnership assets taxable; fixed and agency permanent establishment

13 Dec - Poland: Amendments to decrees on transfer pricing reporting

13 Dec - United States: Consideration of tax consequences in determining arm’s length result (GLAM)

12 Dec - United States: Automatic changes to accounting methods to comply with section 174

12 Dec - United States: Procedures for manufacturers and sellers of clean vehicles to qualify for tax incentives

12 Dec - UAE: Implementation of new federal corporate income tax system, related transfer pricing rules

12 Dec - KPMG report: U.S. administrative law basics for transfer pricing professionals

9 Dec - KPMG report: Public consultation on Amount B under Pillar One

9 Dec - Slovakia: Public country-by-country reporting implemented

9 Dec - UK: HMRC response to consultation on basis period reform issues

9 Dec - UK: Income tax treaty with Brazil signed

9 Dec - UK: Report of national audit office on operation and implementation of digital services tax

9 Dec - United States: Extended deadline is 15 April 2024, for individuals with signature authority (FBAR filings)

9 Dec - EU: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid under EU law (CJEU judgment)

8 Dec - EU: European Commission proposes new tax transparency rules for service providers facilitating cryptoasset transactions

8 Dec - Germany: Ownership of majority voting rights as requirement to form VAT fiscal unity (CJEU judgment)

8 Dec - United States: Special enforcement matters, centralized partnership audit regime (final regulations)

7 Dec - United States and Croatia sign income tax treaty

7 Dec - United States: MAP and the exhaustion of remedies for FTC purposes

7 Dec - Estonia: Recent tax-related developments, including reporting obligations for digital platform operators (DAC7)

7 Dec - Kenya: Minimum tax on gross turnover is unconstitutional (court decision)

6 Dec - Philippines: Guidance regarding payment of penalties for violations of permitted scope of work-from-home arrangements for certain registered business enterprises

6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda

6 Dec - Israel: Tax authority’s intangible property valuation upheld due to insufficient and inconsistent taxpayer documentation (court decision)

6 Dec - Kenya: Apple concentrate for cider subject to 10% duty rate (court decision)

6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed

6 Dec - KPMG report: OECD official provides update on work on Amount B

6 Dec - Romania: Public country-by-country reporting implemented

6 Dec - United States: Certain syndicated conservation easement transactions identified as listed transactions (text of regulations)

5 Dec - Belgium: Reform of periodic VAT returns, debts

5 Dec - Italy: Update on withholding tax on dividends paid to investment funds and related refund opportunities

5 Dec - Nigeria: One-month waiver of penalties and interest on certain tax liabilities

5 Dec - Vietnam: Tax obligations for enterprises creating and using science and technology development fund

2 Dec - United States: IRS provides tax relief for certain taxpayers affected by snowstorm in New York

1 Dec - Belgium: Assessment periods for income tax and VAT extended

1 Dec - Finland: Clarifications on DAC7 reporting obligations

1 Dec - Vietnam: Tax administration rules for e-commerce business activities of family businesses and individuals

November 2022

30 Nov - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

30 Nov - Germany: No exit tax resulting from amendment of income tax treaty (fiscal court decision)

30 Nov - Italy: New rules on import VAT recovery

30 Nov - KPMG report: Transfer pricing in the soccer field

30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced

30 Nov - Poland: Royalty payments to beneficial owner outside EEA not eligible for withholding tax exemption (court decision)

29 Nov - United States: 90-day time limit to file deficiency petition is jurisdictional deadline not subject to equitable tolling (U.S. Tax Court)

29 Nov - United States: Interest rates, tax underpayments and overpayments (increase for first quarter 2023)

29 Nov - Belgium: Interest on foreign regulated savings deposits exempt from individual income tax (court decision)

29 Nov - India: Capital gain not taxable under old India-Mauritius treaty (tribunal decision)

29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics

29 Nov - Netherlands: Floating solar park not considered immovable property subject to VAT (court decision)

28 Nov - China: Advance pricing arrangement annual report for 2021

28 Nov - EU: Anti-money laundering measure allowing access to beneficial ownership information held invalid (CJEU judgment)

28 Nov - Panama: “Extraordinary payment agreements” for tax obligations

28 Nov - Qatar: Transfer pricing documentation requirements

28 Nov - UK: Advisor fees related to potential disposal of subsidiary treated as non-deductible capital expenses (Court of Appeal decision)

22 Nov - EU: Public country-by-country reporting implementation summary

22 Nov - Malta: Formal transfer pricing rules published

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021

22 Nov - Poland: Ratification of treaty with Georgia; MCAA for automatic information exchange under digital platform reporting rules signed

22 Nov - Poland: Recent VAT-related developments (court decisions)

22 Nov - Qatar: Refund of excise tax paid to goods

22 Nov - United States: Rehearing en banc denied in section 965 case (Ninth Circuit)

21 Nov - United States: Colorado (federal retroactive changes applied; includible corporation in unitary combined group); Wisconsin (unclaimed property voluntary disclosure program); Wyoming (roadside services not subject to excise tax)

18 Nov - Costa Rica: Deadline for filing informative tax returns of dormant companies extended to 30 April 2023

18 Nov - Korea: Transfer pricing adjustments with respect to subsidiary loan and subsidiary performance guarantees affirmed (High Court decision)

18 Nov - United States: Guidance relating to the foreign tax credit (text of regulations)

17 Nov - United States: IRS provides tax relief for certain taxpayers affected by storm and flooding in Illinois

17 Nov - Germany: Updated guidance on application of arm’s length principle to cross-border transfers of functions

17 Nov - India: Capitation fees received by educational institution not eligible for exemption available to a charitable trust (court decision)

17 Nov - OECD: Aggregated country-by-country reporting data

17 Nov - South Africa: Proposed withdrawal of practice allowing deduction of interest expense against related interest income

16 Nov - Austria: Changes to reclaim procedure for withholding taxes on dividend distributions

16 Nov - Belgium: Amendments to VAT statute of limitations, retention period and applicable interest rates

16 Nov - Denmark: DAC7 guidance

16 Nov - United States: Procedures for eligible taxpayers to file qualified amended returns

16 Nov - United States: Year-end tax discussion ideas for international tax and transfer pricing

15 Nov - Hungary: Proposed amendments to advance pricing arrangement rules and introduction of public country-by-country (CbC) reporting

15 Nov - Mexico: Increase to state taxes on remuneration for subordinate personal work and drinking water (Baja California state)

15 Nov - Netherlands: VAT recovery based on bank’s “actual use method” (Supreme Court decision)

15 Nov - United States: KPMG comments on proposed regulations providing guidance on IRS Independent Office of Appeals

14 Nov - Italy: Intermediate holding companies in private equity structures served genuine, non-tax purpose (court decisions)

14 Nov - Montenegro: Guidance under new transfer pricing rules

14 Nov - Panama: Benefits granted under “SEM Visa” not unconstitutional (Supreme Court decision)

14 Nov - United States: Georgia (“safe rides fee” subject to sales and use tax); Wisconsin (guidance on taxation of NFTs); multistate (income tax changes approved on election day)

14 Nov - United States: Fair value analysis under satellite radio sourcing rules for franchise tax purposes (Texas appeals court decision)

11 Nov - Bolivia: Fourth group of taxpayers required to issue tax documents through online billing modality

11 Nov - KPMG report: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

11 Nov - Nigeria: Taxation of institutions offering non-interest financial products and services in Nigeria

11 Nov - UK: Implications of interest rate increases for transfer pricing

10 Nov - Czech Republic: Penalty for filing VAT ledger statement for incorrect taxable period struck down (Supreme Administrative Court decision)

10 Nov - Netherlands: Concept of “essentially a new building” for VAT purposes (Supreme Court decision)

10 Nov - OECD: Jurisdictions sign MCAA for automatic information exchange under digital platform reporting rules, CRS disclosure rules

10 Nov - United States: President Biden to nominate Daniel Werfel as IRS Commissioner

9 Nov - United States: Listing notice is legislative rule improperly issued under the Administrative Procedure Act (U.S. Tax Court)

9 Nov - Poland: Cashback discounts do not reduce output tax; correcting invoice does not reduce taxable base (administrative court decisions)

9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)

8 Nov - Belgium: Retroactive application to 2016 of annual tax on credit institutions struck down (Constitutional Court decision)

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

8 Nov - Philippines: Guidance on electronic filing email notification

7 Nov - United States: Missouri (club membership dues subject to sales tax); Oregon (market-based sourcing); Wisconsin (manufacturing credit); multiple states (escheatment rules)

7 Nov - United States: Program for approving 403(b) retirement plans (Rev. Proc. 2022-40)

7 Nov - Mexico: Electronic invoice 4.0 (CFDI 4.0) mandatory beginning 1 April 2023 (three-month extension)

4 Nov - Vietnam: Guidance on various tax-related rules, including e-commerce information reporting

3 Nov - Austria: Inflation relief-related tax measures, DAC7 implementation, guidance on crypto taxation, updated VAT guidelines, other tax developments

3 Nov - FinlandDraft legislation to implement DAC7

3 Nov - Germany: Draft legislation to implement public country-by-country reporting; update on Pillar Two implementation

3 Nov - Hungary: Draft legislation to implement public country-by-country reporting

3 Nov - Netherlands: Dynamic interpretation of tax treaties (Supreme Court decision)

3 Nov - Spain: Dynamic interpretation of tax treaties (Supreme Court decision)

3 Nov - United States: Additional requests for comments on upcoming clean energy tax guidance (IRS notices)

2 Nov - Bahrain: Updated list of goods subject to excise tax

2 Nov - Saudi Arabia: Application of Zakat regulations

2 Nov - United States: CBP announces change to fees for duty-free treatment of infant formula, possible refund opportunities

1 Nov - Hong Kong: Procedure for complying with economic substance requirements under foreign-sourced income exemption regime

1 Nov - Poland: Government approves extension of excise tax exemption for plug-in electric vehicles

1 Nov - Poland: Recent tax developments related to debt for equity swaps, deductibility of team-building event costs (Supreme Administrative Court decisions)

October 2022

31 Oct - Belgium: Tax on securities accounts upheld, but certain anti-abuse measures struck down (Constitutional Court decision)

31 Oct - Singapore: Updates to e-tax guide on R&D tax measures and claim form

31 Oct - UAE: Amended VAT law provisions; new article related to statute of limitations

31 Oct - United States: Combined federal state filing program

31 Oct - United States: Pennsylvania (sourcing of digital audio book sales); South Carolina (fees subject to sales and use tax); Washington State (sourcing of patent procurement services income)

28 Oct - United States: O’Donnell appointed IRS “Acting Commissioner”

28 Oct - Lithuania: Right to charge VAT on sale of immovable property to VAT payer (CJEU judgment)

28 Oct - Netherlands: Proposed legislation implementing cross-border payment reporting obligation beginning 2024

28 Oct - UK: HMRC guidance regarding enterprise management incentives options 

27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget

27 Oct - Germany: Taxpayer may benefit from preferential treatment under any applicable income tax treaty (tax court decision)

27 Oct - Germany: Trade tax treatment of dividend from dual resident corporation (tax court decision)

26 Oct - United States: DOJ will not seek U.S. Supreme Court review of case concerning crude oil tax imposed by section 4611(b)

26 Oct - Qatar: Guidance on submission of no-objection certificate

25 Oct - Belgium: Limitation on dividends received deduction surpluses carried over to absorbing company compatible with EU law (CJEU judgment)

25 Oct - Poland: Updated transfer pricing reporting obligations guidebook

24 Oct - Poland: Transfer pricing measures in legislation amending “Polish Deal”

24 Oct - Uganda: Adjustment of PAYE return for secondary employment income

24 Oct - United States: Illinois (guidance on taxation of cryptocurrency), Maryland (digital advertising tax struck down), multiple states (tax rate changes on ballots)

21 Oct - Costa Rica: Action challenging principle of territoriality as unconstitutional dismissed (court decision)

21 Oct - India: Doctrine of promissory estoppel cannot be invoked against legislative action (Supreme Court decision)

21 Oct - India: Equalization levy could not be imposed on online advertising charges (tribunal decision)

21 Oct - United States: Examination of extended statute of limitations under section 965

20 Oct - Cyprus: Clarification on bilateral Competent Authority Arrangement for exchange of CbC reports with United States

20 Oct - Germany: Penalties for failure to comply with the obligation to keep or provide transfer pricing documentation compatible with EU law (CJEU judgment)

20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive

20 Oct - South Africa: Guidance on definition of “associated enterprises” under transfer pricing rules

19 Oct - India: GST common portal opening extended to file or revise Forms TRAN-1 and TRAN-2 (Supreme Court decision)

19 Oct - India: Six-month extension of Foreign Trade Policy 2015-2020; other trade and customs-related developments

19 Oct - United States: Deadline to file 2019 and 2020 tax returns to get penalty relief postponed in declared disaster areas (IRS reminder)

18 Oct - United States: “Report of Foreign Bank and Financial Accounts” (FBAR)

18 Oct - Bahrain: Preparing for VAT field audits

18 Oct - Korea: Criteria for determining beneficial owner under Austria treaty (tax tribunal decision)

18 Oct - Korea: Transfer pricing adjustments added to customs value of imported goods when directly related (Supreme Court decision)

17 Oct - United States: Mississippi (digital photography service); Tennessee (sales of subscriptions to electronic publications); Texas (web-based weather forecasting service); multiple states (nexus)

17 Oct - Hong Kong: Taxpayers entitled to refund of excessive tax reserve certificates purchased plus interest (court decision)

17 Oct - Poland: Services provided by securitization fund to bank/investment fund qualified as “granting of credit” for VAT purposes (CJEU judgment)

17 Oct - South Africa: MLI to enter into force 1 January 2023

14 Oct - Australia: New income tax treaty with Iceland signed, incorporating BEPS recommendations

14 Oct - KPMG report: Current state and trends in transfer pricing for intercompany financial transactions

14 Oct - OECD: Updated guidance on implementation of country-by-country reporting

13 Oct - United States: Partnership distribution of “clients” was distribution of intangible assets (U.S. Tax Court)

12 Oct - United States: Calendar year corporate income tax return filing deadline extended to November 15, 2022 (Illinois)

12 Oct - United States: IRS updates FAQs on QI / WP / WT website, certifications and periodic reviews

12 Oct - Bahrain: Updated VAT registration guideline; new decision for digital stamp scheme

12 Oct - KPMG report: Transfer pricing considerations in the age of precision medicine

11 Oct - Lithuania: Supply recipient may deduct VAT even though supplier did not pay output VAT (CJEU judgment)

11 Oct - Nigeria: VAT is principal tax on goods and services in hotels, restaurants and event centers (court decision)

11 Oct -  United States: Additional permitted election changes for health coverage under “cafeteria plans”

11 Oct - United States: IRS expands penalty relief for dyed diesel fuel in Florida; hurricane-related relief

11 Oct - United States: Taxpayer assistance procedures for S corporations under section 1362(f)

10 Oct - United States: Colorado (streaming platform credits); New York (nontaxable information services); Oregon (business license tax law); South Dakota (bank franchise tax)

10 Oct - United States: Penalties on unified annual reconciliation of apportionable income (Washington State)

10 Oct - India: Appellant can pay 10% of disputed tax using either electronic cash or credit ledger (high court decision)

7 Oct - United States: Extended temporary relief, low-income housing credit under section 42 (Notice 2022-52)

6 Oct - United States: FBAR filing deadline relief for persons affected by certain natural disasters

5 Oct - United States: Requests for comments on upcoming clean energy tax guidance (IRS notices)

5 Oct - United States: IRS provides tax relief for taxpayers affected by Hurricane Ian (North Carolina and South Carolina)

5 Oct - Australia: ATO guide on tax reporting of cryptoassets

4 Oct - Germany: Disallowance of final losses incurred by UK permanent establishment upheld (CJEU judgment)

4 Oct - Philippines: Guidelines and procedures for requesting MAP

3 Oct - Mexico: Procedures for employer to obtain opinion on compliance with social security tax obligations

3 Oct - Poland: Recent tax developments relating to holding structure, deduction cap for intangible services (Supreme Administrative Court decision)

3 Oct - United States: Colorado (retail delivery fee guidance); Iowa (corporate income tax rate reduction); Texas (R&D credit); West Virginia (tax preparer must collect sales tax)

3 Oct - United States: IRS announces new sign-in system for QI / WP / WT application and account management system (QAAMS)

September 2022

30 Sep - Belgium: Guidance on VAT refund procedures and remunerations in football

30 Sep - Portugal: EU General Court upholds EC’s determination that tax benefits in Madeira free zone not correctly applied

30 Sep - Slovakia: Proposed changes to transfer pricing rules and limitations on deductibility of interest

30 Sep - United States: IRS to waive dyed diesel fuel penalty in Florida; hurricane-related relief

29 Sep - Canada: Increased audit activity related to annual federal 10% excise tax on cross-border insurance premiums

29 Sep - Canada: Changes to customs importer of record rules, implications for e-commerce importers

29 Sep - Italy: Swiss social security institute entitled to withholding tax refund; possible refund opportunities (Supreme Court decision)

29 Sep - Puerto Rico: Tax-related hurricane relief

29 Sep - South Africa: Increased transfer pricing scrutiny

29 Sep - Spain: Challenge to Spanish tax leasing system (CJEU Advocate General opinion)

29 Sep - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Ian

28 Sep - Bahrain: Access to taxpayer "relationship manager" details

28 Sep - Belgium: Deadline for filing Local file forms is 17 October 2022

28 Sep - Germany: Draft legislation on implementation of DAC7 and modernization of tax procedures law

28 Sep - Germany: Draft legislation on submission of transfer pricing documentation in tax audit

28 Sep - Germany: Withholding tax exemption denied (lower tax court decision)

28 Sep - Switzerland: Tax-related information exchange with Russia suspended, including country-by-country (CbC) reports

27 Sep - Hong Kong: Procedure for confirming economic substance under revised exemption regime

27 Sep - Philippines: Electronic filing, filing of returns, payment of taxes extended

27 Sep - United States: IRS provides tax relief for certain taxpayers affected by storms in Alaska

26 Sep - Malaysia: Extension of payment period under second phase of voluntary disclosure program for indirect taxes

26 Sep - United States: Colorado (cryptocurrency as payment for taxes); Illinois (abatement of late penalties); Louisiana (manufacturing allocation formula)

26 Sep - United States: Excess loss account included in income of consolidated group member (U.S. Tax Court)

26 Sep - United States: Extension of time to amend certain eligible retirement plans for qualifying distributions

26 Sep - United States: LB&I memo providing updated guidance on the statute of limitations with respect to section 965 examinations

22 Sep - Canada: Pension plan contributions and employment insurance apply to restaurant tips (court decision)

22 Sep - Finland: Withholding tax refunds for Luxembourg SICAV funds

21 Sep - Bahrain: Deadline for ultimate parent entity of MNE resident in Bahrain to file country-by-country (CbC) report

19 Sep - Belgium: DAC6 legislation held invalid, questions raised to CJEU (Constitutional Court decision)

19 Sep - India: Guidance regarding withholding on benefits arising from recipient’s business or profession

19 Sep - Korea: Arm’s length interest rate on late-paid trade receivables; use of APA application information (Tax Tribunal decisions)

19 Sep - Korea: Preferential tariff rate under Korea-ASEAN free trade agreement; customs value based on fallback method (Tax Tribunal decisions)

19 Sep - UK: Increased HMRC scrutiny of R&D claims

19 Sep - United States: IRS provides tax relief for taxpayers in Puerto Rico affected by Hurricane Fiona

19 Sep - United States: “Qualified disaster” declaration allowing employer-sponsored charities to provide relief (Puerto Rico)

19 Sep - United States: IRS updates information on pre-screening and certification process of Work Opportunity Tax Credit (WOTC)

19 Sep - United States: Updated Technical Guide on exemption of certain business leagues and boards

19 Sep - United States: Sales and use tax manufacturing exemption (Missouri), service contract subject to sales and use tax (North Carolina), sales and use tax collection by out-of-state sellers (Pennsylvania), bookstore membership fees subject to sales and use tax (South Carolina)

16 Sep - United Kingdom: Anti-treaty shopping rule under Irish treaty did not apply to deny withholding tax relief on interest income (court decision)

16 Sep - United States: Unclaimed property voluntary compliance program legislation enacted (California)

15 Sep - Gibraltar: Rule preventing double taxation of amounts recovered as unlawful state aid may be applied (CJEU judgment)

15 Sep - Luxembourg: Increased scrutiny on FATCA and CRS compliance

15 Sep - United States: IRS opens application period for 2023 Compliance Assurance Process (CAP) program

15 Sep - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU Advocate General opinion)

14 Sep - UK: Taxation of cross-border intragroup asset transfer not contrary to EU law (CJEU Advocate General opinion) 

14 Sep - Germany: Holding company has no right to recover VAT on services contributed to subsidiary (CJEU judgment)

13 Sep - Czech Republic: Proposed record keeping and reporting obligation for payment service providers beginning 2024

12 Sep - Spain: Deadline to claim VAT refunds for 2021 is 30 September 2022

9 Sep - India: Application of “most favoured nation” clause under treaty with the Netherlands (tribunal decision)

9 Sep - United States: Guidance relating to IRS Independent Office of Appeals (text of proposed regulations)

6 Sep - Mexico: Proposed seventh modification to miscellaneous tax resolution 2022, changes to tax-related penalties

6 Sep - Poland: Recent tax developments relating to company reorganizations, lump-sum income tax, e-signing returns

6 Sep - South Africa: Tax authority to issue letters requesting specific corporate documents; supplementary declaration forms (IT14SD) discontinued

6 Sep - UK: Updated HMRC guidance on making tax digital for income tax self-assessment

2 Sep - Cyprus: Non-deductible input VAT on acquisition of apartment under Cypriot Investment Program (tribunal decision)

2 Sep - United States: IRS provides tax relief for taxpayers affected by water crisis (Mississippi)

1 Sep - Denmark: Reminder of 6 September deadline for transfer pricing documentation

1 Sep - Philippines: Guidance on lifting suspension of field audit and operations

August 2022

30 Aug - United States: Rules for determining stock ownership under section 958

30 Aug - Malta: Record keeping and reporting obligations for payment service providers beginning 2024

30 Aug - Mexico: Transfer pricing documentation for derivative financial transactions

29 Aug - Poland: Recent tax developments relating to robotization (Supreme Administrative Court decision)

29 Aug - Poland: Transfer pricing measures in draft bill

26 Aug - Bulgaria: MLI ratified

26 Aug - EU: Taxation-based obstacles and distortions in cross-border investment; regulation of intermediaries in the EU (European Parliament)

26 Aug - Finland: Mandatory disclosure rules (DAC6) reporting assessment published

26 Aug - OECD: Peer review reports on transparency and exchange of information on request

26 Aug - Slovenia: Public consultation on implementation of directive for income earned by digital platforms (DAC7)

26 Aug - Switzerland: Public consultation on draft ordinance regulating minimum taxation in Switzerland (Pillar Two)

25 Aug - Australia: Entities paying notional GST have rights of appeal in federal courts (Federal Court decision)

25 Aug - Finland: Updated FATCA and CRS FAQs

25 Aug - Luxembourg: Penalties related to real estate levy reporting obligation assessed

25 Aug - Nigeria: Reminder of 31 August 2022 deadline for filing companies income tax returns for 2022

25 Aug - OECD: Comments on progress report on Amount A of Pillar One

25 Aug - United States: Partnership’s payments to lender were deductible interest, and not payments on an equity interest (U.S. Tax Court)

25 Aug - United States: Sixth Circuit affirms Tax Court decision that taxpayer not liable for 40% penalty upon cancellation of APAs

24 Aug - United States: Penalty relief for certain taxpayers filing returns for tax years 2019 and 2020

24 Aug - United States: Early distribution 10% exaction is tax, not a penalty requiring written supervisory approval; Tax Court affirmed (Second Circuit)

24 Aug - Germany: Law amending interest on back taxes and tax refunds effective 22 July 2022

24 Aug - Germany: Real property management company premises can be permanent establishment of contracting company (tax court decision)

24 Aug - Ireland: Updated reporting entity registration form for FATCA, CRS purposes

24 Aug - Mexico: Penalties and sanctions do not apply to noncompliant electronic invoices with consignment note complement

23 Aug - KPMG report: Implementation of ATAD I and II by EU Member States

23 Aug - Philippines: New letter of authority must be issued if tax investigation reassigned

23 Aug - Vietnam: FATCA FAQs for 2021-2022 reporting

22 Aug - Poland: Deductibility of expenses incurred on behalf of third party; required information for individual ruling (court decisions)

18 Aug - United States: Tax Court’s determination of transfer pricing method, on remand from Eighth Circuit

18 Aug - United States: IRS Appeals invites input on enhancing video conferences

17 Aug - Canada: Mandatory disclosure rules proposed to apply beginning 2023

17 Aug - Canada: Possible changes to general anti-avoidance rule (GAAR), comments due 30 September 2022

16 Aug - UAE: New service for voluntary disclosure of errors on customs declarations

15 Aug - Costa Rica: Extension of deadline for filing dormant entities tax returns

15 Aug - United States: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2022)

12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information

12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes

11 Aug - EU countries: Transposition of EU directive, cross-border distributions of collective investment undertakings

11 Aug - Nigeria: No retroactive application of tax law changes unless expressly stated (court decision)

11 Aug - Hong Kong: Company directors not liable for additional taxes for incorrect profits tax returns filed by company (court decision)

10 Aug - Hong Kong: Income tax treaties to be modified by MLI

10 Aug - British Virgin Islands: Amendments to FATCA and CRS legislation

10 Aug - Italy: Tax audits based on cross-border transactions, transfer pricing issues

10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures

9 Aug - Czech Republic: Guidance provided in Q&As on cross-border arrangement reporting under DAC6

9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance

9 Aug - Poland: Tax authority’s access to banking information of taxpayers subject to proceedings

9 Aug - United States: JCT revenue estimates and distributional analysis of budget reconciliation bill

9 Aug - United States: Legislative text of reconciliation bill with tax provisions

8 Aug - Hong Kong: Salaries tax treatment of share award; vesting vs. forfeiture (court decision)

8 Aug - Panama: Extension for updates to taxpayer registry, due 31 August 2022

8 Aug - UK: Commercial transaction structured in tax-efficient way did not have “main purpose” of tax avoidance (court decision)

8 Aug - UK: Deduction of interest on intragroup loan used for third-party acquisition disallowed (court decision)

8 Aug - UK: HMRC “claw back” of coronavirus job retention scheme (CJRS) grants for noncompliance (court decision)

5 Aug - Austria: Implementation of DAC7 and reporting requirements for digital platform operators

5 Aug - South Africa: Tax authority targets e-service suppliers and VAT compliance

5 Aug - United States: Partnership upheld as valid, despite IRS claims it never would have been profitable without refined-coal tax credits (D.C. Circuit)

5 Aug - United States: Deductions denied for deferred cash payments of $51 million made to former spouse (Eighth Circuit)

5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency

4 Aug - Australia: Proposal to require reporting by digital platforms

4 Aug - Philippines: Suspension lifted, certain tax compliance actions of revenue officers

4 Aug - UAE: AEOI portal FAQs under FATCA and CRS regimes

4 Aug - United States: Removal of signature requirement for section 754 elections

4 Aug - United States: Credit for renewable fuels reduces excise tax, but deduction limited to excise tax actually paid (Fifth Circuit)

3 Aug - United States: Initial impressions of corporate alternative minimum tax provision in draft Senate reconciliation bill

2 Aug - Bolivia: Guidance concerning tax payment facilities

2 Aug - EU: Proposed directive for debt-equity bias reduction allowance and limiting deductibility of interest for corporate income tax purposes (KPMG comments on DEBRA proposal)

2 Aug - Hong Kong: Intra-group share transfer involving UK LLPs eligible for stamp duty relief (court decision)

1 Aug - Bolivia: Revised rules regarding failure-to-pay penalty

July 2022

29 Jul - Lithuania: Changes to APA rules

28 Jul - Bolivia: Guidance to implement tax administrative and procedural legislative measures

27 Jul - OECD: Progress on harmful tax practices

27 Jul - Singapore: Updated FATCA document for record level errors

27 Jul - UAE: Deadline to file FATCA and CRS reports is now 15 August 2022

27 Jul - United States: Reported agreement on Senate reconciliation bill, legislative text and summary of bill

26 Jul - Bolivia: Revised tax administrative and procedure measures

26 Jul - EU wins WTO case against Turkey's “discriminatory practices” regarding pharmaceutical products

26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw

26 Jul - Poland: Excise goods introduced into free zone exempt from excise markings obligation (court decision)

26 Jul - Poland: No transfer pricing documentation or Local file reporting obligation on contribution to foreign company’s supplementary capital

26 Jul - United States: Taxpayer’s claim for reimbursement of “protest payments” denied, no statutory basis for refund (Eleventh Circuit)

26 Jul - United States: Allowance of deductions and credits on Form 1120-F delinquent returns

25 Jul - Cambodia: Site visits by tax authority to enterprises in Phnom Penh

25 Jul - India: Amendment with respect to nondeductible expenses does not have retroactive effect (high court decision)

25 Jul - India: Guidance that deferred payments for road construction not exempt from GST held invalid (high court decision)

25 Jul - UK: HMRC consultation on collecting data from taxpayers

25 Jul - UK: New transfer pricing documentation rules effective for accounting periods beginning on or after 1 April 2023

 

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