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2 Oct - United States: Foreign tax credit—categorization of income and taxes into proper basket (updated August 1)

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)

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

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

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)

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

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

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

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”

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)

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

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

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 - Finland: Draft 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)

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)

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

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

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

21 Jul - EU: Tax-related developments from CJEU, EU Council, European Commission, and EU Parliament

25 Jul - United States: JCT revenue estimates of tax proposals in Biden Administration’s FY 2023 budget

20 Jul - Australia: ATO guidance on treaty shopping arrangements

20 Jul - Greece: Legislation incorporating ATAD measures for reverse hybrid instruments

20 Jul - Mexico: Condition provided in procedure file 85/CFF relating to CFDI held unconstitutional (court decision)

20 Jul - UK: Draft legislation to implement Pillar Two published

19 Jul - United States: IRS Chief Counsel Memorandum on penalties under proposed electronic-filing requirements

19 Jul - Germany: “Transfer of functions” proposal to align arm’s length principle with OECD Transfer Pricing Guidelines

19 Jul - Poland: Pre-consultation on assumptions for digital platform owners (DAC7)

18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency

18 Jul - Czech Republic: Waiver of default interest on VAT granted (Supreme Administrative Court decision)

18 Jul - India: Election by export-oriented undertaking must be filed by due date of original return (Supreme Court decision)

18 Jul - KPMG report: The diverging paths of Pillars One and Two

18 Jul - Netherlands: Interest deductions in acquisition structures (Dutch Supreme Court)

16 Jul - United States: Tax treaty with Hungary terminated

15 Jul - Australia: ATO self-review guide and toolkit under FATCA and CRS regimes

15 Jul - Germany: Proposals regarding transfers of functions, transfer pricing documentation, transposition of DAC7

14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council

14 Jul - Italy: Withholding tax on dividends paid to U.S. collective investment funds; refund opportunities (Supreme Court decision)

13 Jul - Germany: Updated CRS guidance

12 Jul - China: Readjusted scope of voluntarily disclosures of customs adjustments

12 Jul - India: Company earned income upon conversion of compulsory convertible debentures (tribunal decision)

12 Jul - Poland: Excise duty regulations compliant with EU directive, VAT on chain transactions (CJEU action)

12 Jul - Netherlands: New decree on profit attribution to permanent establishments

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

11 Jul - Cyprus: Transfer pricing documentation legislation

11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation

11 Jul - Philippines: Guidance regarding service of electronic letter of authority

11 Jul - Romania: Amendments to FATCA and CRS regimes

8 Jul - Germany: Updated CRS guidance

8 Jul - Netherlands: Policy statement on VAT fixed establishments reflects position change

8 Jul - United States: IRS releases PLR, granting consent to taxpayer’s request regarding cost-sharing arrangement and intangible development costs

8 Jul - United States: IRS summons to taxpayer not quashed despite criminal referral of taxpayer’s agent (Fourth Circuit)

7 Jul - Italy: Withholding tax on services provided by property intermediation platform via internet (CJEU Advocate General opinion)

7 Jul - Netherlands: Details about changes in new transfer pricing decree

5 Jul - EU: Tax-related actions of CJEU, EU Council, European Commission, and EU Parliament

5 Jul - Nigeria: Extended deadline for filing companies income tax returns for 2022

5 Jul - Poland: Transfer pricing measures in proposed legislation

1 Jul - Netherlands: Allocation of debt and equity to PE, other transfer pricing issues (appellate court decision)

1 Jul - Netherlands: New transfer pricing decree

1 Jul - United States: Appeals court holds vacation home is not permanent place of abode (New York State)

30 Jun - Cayman Islands: Updated CRS enforcement guidelines

30 Jun - Germany: Amendments to FATCA and CRS regimes

30 Jun - South Africa: VAT on indemnity payments not deductible (court decision)

29 Jun - Channel Islands: FATCA and CRS reporting deadline is 30 June 2022 (Jersey)

29 Jun - Malaysia: Extension of payment period under voluntary disclosure program for indirect taxes

29 Jun - Slovakia: Implementation of EU directive on reporting obligations of digital platforms (DAC7)

28 Jun - United States: JCT overview of federal tax system (2022)

28 Jun - Germany: Amended dual consolidated loss rule cannot be applied retroactively (lower tax court decision)

28 Jun - Germany: Amendment to interest on back taxes and tax refunds

28 Jun - Germany: Application of anti-treaty/directive shopping rule to interest on convertible bond (tax court decision)

28 Jun - Malta: Update on transfer pricing landscape

28 Jun - Philippines: Tax audits, compromise penalties (court decisions)

28 Jun - Poland: Meaning of “one-off transaction value”; dividend income taken into account in allocating indirect costs (Supreme Administrative Court decisions)

27 Jun - UK: Background and implications of delayed implementation of Pillar Two

27 Jun - United States: Iowa (sales and use tax changes); Oregon (certiorari denied in case concerning VoIP collection of E-911 tax); Washington State (Seattle payroll expense tax upheld, certiorari denied in case concerning B&O tax surcharge financial institutions)

24 Jun - United States: Energy efficient commercial buildings deduction (IRS practice unit)

24 Jun - Australia: Cryptocurrencies not regarded as foreign currency for tax purposes

24 Jun - India: Guidance on tax withholding, transfers of virtual digital assets

22 Jun - Germany: Dividend withholding tax refund rules; reimbursing withholding tax on dividends received from portfolio investments (CJEU judgment)

21 Jun - Cambodia: Guidance regarding loans between related parties; interest rate and supporting documentation

21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy

21 Jun - Poland: Update on mandatory e-invoicing, proposed extension of 0% VAT rate to support Ukraine

21 Jun - United States: Supreme Court grants certiorari, whether penalty for FBAR violation applies on per-account or per-form basis

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

17 Jun - EU: Latest court decisions, CJEU referral, EC and European Parliament developments

17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting

17 Jun - India: Updated guidance for mutual agreement procedure (MAP)

17 Jun - Pakistan: AEOI implementation manual

16 Jun - United States: Transfer pricing settlement initiative program for corporate taxpayers (New Jersey)

15 Jun - Bolivia: Increased penalties regarding noncompliant invoices

15 Jun - Malaysia: Delinquent taxpayers identified, enforcement proceedings planned

15 Jun - United States: “Innocent spouse relief” not available as defense for trust fund recovery penalty liability (U.S. Tax Court)

15 Jun - United States: Proposed changes to R&D regulations, sales tax exemption or franchise tax credit (Texas)

15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One

14 Jun - OECD: Tax transparency in Africa 2022

14 Jun - India: Offshore commission income earned by foreign company not taxable in India (tribunal decision)

14 Jun - Poland: Deductibility of U.S. withholding tax on dividends (court decision)

14 Jun - Portugal: VAT rate for elevator repairs and maintenance (CJEU judgment)

14 Jun - UK: Implementation of Pillar Two delayed

10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One

10 Jun - Luxembourg: New income tax treaty with UK is signed

10 Jun - Singapore: GST zero-rating for exported goods “hand-carried” by motor vehicle (court decision)

10 Jun - UK: CFC group finance company partial exemption rules constitute unlawful state aid (EU General Court)

9 Jun - OECD: New transfer pricing country profiles for Egypt, Liberia, Saudi Arabia, and Sri Lanka

9 Jun - South Africa: Third-party data annual submissions process for AEOI closed

8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021

7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country

7 Jun - Netherlands: Transfers of real property qualified as transfers of going concern for VAT purposes (court decisions)

7 Jun - Philippines: Tax audit and field operations of task forces suspended

7 Jun - United States: FATCA responsible officer certifications due 1 July 2022

7 Jun - United States: Future of consumer and retail—transfer pricing perspective

7 Jun - United States: Mandatory repatriation tax under section 965 is constitutional (Ninth Circuit)

6 Jun - Bolivia: Proposals to modify procedural rules regarding tax remittances, related penalties

6 Jun - Poland: Finance Minister’s reply to parliamentary inquiry regarding transfer pricing information

6 Jun - Poland: Reduced interest rate on voluntary payments, exchange rate for corrective VAT invoices (court decisions)

3 Jun - Saint Lucia: Updated CRS guidance

2 Jun - Barbados: AEOI portal for 2021 submissions open until 31 August 2022

1 Jun - United States: Comments submitted to IRS regarding plans to update MAP and APA guidelines

31 May - Germany: Withholding tax on provision of the use of know-how for unlimited period of time (court decision)

31 May - Poland: Debts that are sold can no longer be charged into tax-deductible costs (court decision)

31 May - Poland: Fixed establishment of German entity under VAT law (court decision)

31 May - Slovakia: Tax administration aims to remove duplicate taxpayer accounts from portal

27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation

26 May - United States: IRS releases tax collection data for fiscal year 2021

25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation

25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One

25 May - Taiwan: Extension of CRS reporting deadline

25 May - Thailand: Voluntary disclosure program regarding import and export transactions, extended into 2026

24 May - EU: Status regarding proposal for EU minimum tax directive

24 May - EU: CJEU infringement procedure and referral; developments from EC, European Parliament, and OECD

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

23 May - Costa Rica: Guidance regarding suspended deadlines for procedures before tax administration

23 May - Germany: Initiation of FATCA submission reporting period 2021

23 May - India: Beneficial ownership provisions may not apply to capital gains article of India-Mauritius treaty (tribunal decision)

23 May - India: No GST payable by Indian importer on reverse charge on ocean freight paid by foreign seller (Supreme Court decision)

23 May - Netherlands: Supreme Court decisions in cases concerning “Box 3” (wealth tax)

23 May - UAE: Voluntary disclosure penalties under revised tax-related penalty regime

20 May - China: Shenzhen launches first tax and customs collaborative transfer pricing management mechanism

20 May - Sweden: Guidance regarding permanent establishment determinations for employees working from home

20 May - United States: Interest rates, tax underpayments and overpayments (increase for third quarter 2022)

19 May - France: “Précompte” system of dividends taxation is contrary to EU law (CJEU judgment)

19 May - UK: Amendment to FATCA and CRS regulations

18 May - United States:  KPMG report on proposed changes to qualified intermediary (QI) agreement (Notice 2022-23)

17 May - United States: Taxpayer did not qualify as small insurance company; Tax Court decision affirmed (Tenth Circuit)

17 May - United States: Taxpayer prevails in capital gain tax dispute on statutory, but not constitutional ground (Massachusetts)

17 May - Luxembourg: FAQ on mandatory disclosure rules (DAC6)

16 May - China: CRS reporting deadline extended to 30 June 2022

16 May - India: Guidance regarding notices issued under old reassessment regime (Supreme Court decision)

16 May - India: Training cost reimbursements not taxable as fees for included services under India-U.S. treaty (tribunal decision)

16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax

16 May - UK: Determining whether a contract is within the scope of the off-payroll working rules (court decisions)

16 May - Vietnam: Measures to strengthen tax administration for e-commerce activities

13 May - United States: Six-month extension allowing retirement plan elections and spousal consents to be signed remotely

11 May - United States: Tax return considered filed when sent in response to IRS inquiry; Tax Court reversed (Ninth Circuit)

11 May - EU: Developments from CJEU Advocate General, European Parliament, and OECD

11 May - India: Determining value of land as part of construction contract for GST purposes (court decision)

11 May - Vietnam: Recommended focus on tax audit and inspection of high-risk industries and areas

10 May - Czech Republic: Additional tax assessment based on overall profitability for unrelated-party transactions (court decision)

10 May - India: No permanent establishment under India-Singapore tax treaty (tribunal decision)

9 May - Israel: Court decision on business restructuring and deemed transfer of business functions, assets and risks

9 May - Malaysia: Updated tax audit frameworks

9 May - Switzerland: Transfer pricing controversy statistics, including effects of COVID-19

6 May - Malta: FAQs on mandatory disclosure rules (DAC6)

6 May - Netherlands: Considerations for companies in scope of Pillar Two rules

6 May - New Zealand: Consultation on implementation of Pillar Two rules

6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation

6 May - United States: Allocation and apportionment of deferred compensation expense for purposes of calculating FDII—departure from prior IRS legal advice

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

5 May - Singapore: Updated guidance on FATCA and CRS return filing

5 May - India: Notice issued under old reassessment regime deemed issued under new reassessment regime (Supreme Court decision)

4 May - India: Guidance on filing updated tax returns

4 May - Nigeria: Summary of tax transparency reporting developments

4 May - OECD: Tax transparency in Latin America 2022

4 May - Poland: Transfer pricing reporting changes

3 May - Italy: Withholding tax exemption on cross-border interest payments applied on look-through basis (court decision)

3 May - KPMG report: Transfer pricing planning 2.0

3 May - KPMG report: Why operationalizing transfer pricing is more important than ever

3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update

3 May - United States: Proposed changes to QI withholding agreement for dispositions of publicly traded partnership interests (Notice 2022-23)

2 May - Bermuda: CRS registration and reporting deadlines extended

2 May - Cayman Islands: Penalty regime under CRS enforcement guidelines

2 May - OECD: Comments on tax transparency framework for crypto-assets, proposed amendments to CRS

2 May - UAE: Consultation on new federal corporate income tax system

2 May - UK: Significant changes to taxation of professional partnerships

2 May - UK: Transfer pricing statistics (FY 2021)

2 May - UK: Withholding tax on manufactured overseas dividends allowed under EU law (Supreme Court decision)

2 May - United States: Minnesota (credit card surcharges subject to sales tax); New York (free gift cards subject to sales tax); Oklahoma (expanded marketplace facilitator definition)

29 Apr - Hong Kong: Profits found to be offshore-sourced, not subject to profits tax (court decision)

28 Apr - Luxembourg: Tax exemption under participation regime, beneficial ownership and withholding tax refunds (court decisions)

28 Apr - Spain: Requirements for invoicing computer software and standardized record format

27 Apr - Belgium: Requirement to report information about tourist accommodations not contrary to EU law (CJEU judgment)

27 Apr - EU: CJEU, General Court, European Parliament, and OECD updates (April 2022)

27 Apr - EU: Recommendation to strengthen VAT cooperation with Norway

27 Apr - United States: FATCA IDES testing, scheduled for June 2022

26 Apr - Germany: Arrangements for cross-border workers extended for the last time through June 2022

26 Apr - Germany: Contribution gain II due to change of legal form (court decision)

26 Apr - Germany: Disallowance of final losses incurred by UK permanent establishment held valid (CJEU Advocate General opinion)

26 Apr - United States: Country-by-country (CbC) report in the transfer pricing risk analysis process (IRS practice unit)

26 Apr - United States: Expert witness testimony excluded and deductions for management fees denied; Tax Court affirmed (Eighth Circuit)

26 Apr - United States: Request for recommendations for IRS 2022-2023 Priority Guidance Plan

25 Apr - United States: Australian freight forwarding company agrees to pay over $6 million to settle violations of sanctions regulations

25 Apr - United States: Sanctions regarding Russia, FAQs and general licenses

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

25 Apr - Chile: Instructions for mutual agreement procedure under income tax treaties, recent VAT developments

22 Apr - Gibraltar: Exemption regime for royalties constitutes unlawful state aid (EU General Court)

22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

22 Apr - United States: Tax credit applied against fuel excise tax reduces excise tax liability (Sixth Circuit)

21 Apr - United States: 30-day time limit to petition for review of collection determination subject to equitable tolling (U.S. Supreme Court)

21 Apr - Channel Islands: No change in deadline for FATCA and CRS reporting (Guernsey)

21 Apr - Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022

20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

20 Apr - KPMG report: Transfer pricing and the audit committee agenda

20 Apr - Mexico: Considerations for maquiladora transfer pricing strategy, given elimination of APAs

20 Apr - Philippines: Deadline for submission of attachments to 2021 income tax returns

20 Apr - United States: Targeting entities and individuals evading sanctions on Russia

20 Apr - Zimbabwe: Extended deadlines for corporate income tax and transfer pricing returns for 2021

20 Apr - India: Reassessment notice emailed on last day of limitation period held valid (court decision)

19 Apr - India: Payments to subcontractor in China taxable as fees for technical services under India-China treaty (tribunal decision)

19 Apr - Netherlands: “Box 3” (wealth tax) and restoration of rights; future and pending legal proceedings

19 Apr - Poland: Real estate reporting; taxpayer information sharing; tax-deductible costs; auxiliary services and VAT

18 Apr - United States: Certiorari denied in states’ challenge to 2017 tax law limiting SALT deduction (U.S. Supreme Court)

18 Apr - United States: IRS reminds employers of penalty relief related to claims for employee retention credit

15 Apr - Luxembourg: Implementation of TIN field instructions for FATCA reporting purposes

15 Apr - Malaysia: Tax corporate governance framework and guidelines

15 Apr - United States: Superfund excise taxes, relief regarding failure to deposit penalties (Notice 2022-15)

14 Apr - KPMG report: Comments on implementation framework of global minimum tax

14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax

14 Apr - OECD: Comments on implementation framework of global minimum tax

14 Apr - Poland: Ruling on application of new rule on depreciation for real estate companies

13 Apr - Belgium: Compatibility of EU mandatory disclosure rules (DAC6) notification obligations with EU law (CJEU Advocate General opinion)

13 Apr - Cayman Islands: Updated CRS guidance

13 Apr - EU: International tax developments, possible domestic and cross-border implications

13 Apr - Luxembourg: Updated CRS FAQs

12 Apr - United States: At-home private nurses were employees for federal employment tax purposes (U.S. Tax Court)

12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines

12 Apr - KPMG report: OECD’s proposed crypto-asset reporting framework

12 Apr - Zambia: Country-by-country reporting rules for 2021 tax year

11 Apr - Australia: Tax and transfer pricing implications of IBOR reform

11 Apr - India: Subscription fees not taxable under tax treaty with Singapore; e-dispute resolution scheme

11 Apr - Kenya: Proposed reporting requirements for multinational entities

11 Apr - United States: Maryland (no tax liability for tribe); Oklahoma (date for refund claim); Washington State (B&O tax apportionment for Tacoma)

8 Apr - United States: Gain recognized by cooperative upon sale of partnership interests is patronage-sourced income (PLR)

8 Apr - Romania: Determining VAT liability when affiliated entity or subsidiary provides services and resources (CJEU judgment)

7 Apr - Finland: French corporate-form fund held comparable with contractual-based fund; refund opportunities (CJEU judgment)

7 Apr - India: No dependent agent permanent establishment under India-Mauritius tax treaty (tribunal decision)

7 Apr - India: Payments for online advertisements not taxable in India (tribunal decision)

7 Apr - Netherlands: Update on bill to implement EU Directive on reporting obligations of digital platforms (DAC7)

6 Apr - United States: Payments to Russian scientist—taxable compensation or exempt from tax as a grant? (Fourth Circuit)

6 Apr - United States: Accounting for deferred fees using GAAP by retirement community upheld (U.S. Tax Court)

6 Apr - KPMG report: Comments in response to EU public consultation on “Unshell” Directive proposal

6 Apr - KPMG report: Tariffs on imports from China held valid (U.S. trade court decision)

5 Apr - Channel Islands: FATCA and CRS compliance information (Guernsey)

5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)

5 Apr - Germany: Updated CRS guidance concerning refugees from Ukraine

5 Apr - India: Tax withheld at source and deductibility of related expenses; foreign tax credit on taxes withheld in Singapore

5 Apr - OECD: New inventory of tax technology initiatives

5 Apr - United States: Temporary regulations under section 245A held invalid (federal district court)

4 Apr - United States: Arkansas (nexus and apportionment); Kentucky (corporate, individual and indirect tax measures); Oregon (source of receipts)

4 Apr - Australia: Trade agreement with India

4 Apr - Malaysia: New e-telegraphic transfer system for tax payments

4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested

4 Apr - Poland: Reporting by real estate companies; interest on tax overpayments by foreign investment funds

1 Apr - France: Administrative guidance regarding digital services tax held invalid (Conseil d'Etat decision)

1 Apr - Poland: Update on mandatory use of electronic invoices, VAT implications

1 Apr - Thailand: Extended deadline for filing transfer pricing disclosure form for 2020

1 Apr - UK: Costs for gas storage cavities do not qualify for capital allowances (Court of Appeal decision)

1 Apr - UK: Deductions for lapsed employee share options (Supreme Court decision)

1 Apr - United States: Company agrees to pay $79,000 to settle transactions in 2016 and 2017 in violation of Ukraine-related sanctions

31 Mar - United States: Deferred compensation received by nonresident alien individuals (IRS practice unit)

31 Mar - United States: Fees for use of securities exchanges not deductible under section 199 (U.S. Tax Court)

30 Mar - United States: APMA program, APA statistics for 2021 (IRS Announcement 2022-7)

30 Mar - United States: International tax proposals in Biden Administration’s budget for FY 2023

30 Mar - Antigua and Barbuda: AEOI CRS compliance form introduced

30 Mar - Bolivia: Taxpayers required to issue digital tax documents

30 Mar - EU: CJEU, European Commission, European Parliament, and OECD updates (March 2022)

29 Mar - Channel Islands: Guidance for FATCA and CRS reporting financial institutions (Guernsey)

29 Mar - Dominican Republic: Proposal to revise tax procedural and administrative rules

29 Mar - India: Procedures for examining GST returns for FY 2017-18 and FY 2018-19

29 Mar - OECD: IT-format to support global tax reporting framework for digital platforms

28 Mar - Angola: Transfer pricing implications of updated list of “large taxpayers”

28 Mar - Germany: Attribution of profits of permanent establishment without personnel (court decision)

28 Mar - Germany: Draft law amending interest on back taxes and tax refunds

28 Mar - Nigeria: Security deposit before taxpayer can proceed with tax appeal (tribunal decision)

28 Mar - United States: “Green Book”—Treasury’s explanation of tax proposals (FY 2023 budget)

28 Mar - United States: Initial document is released (FY 2023 budget)

28 Mar - United States: Butane not eligible for tax credit; tax on exports of domestic crude oil held unconstitutional (Fifth Circuit)

25 Mar - United States: Comptroller’s sourcing position in satellite radio case rejected by state’s high court (Texas)

25 Mar - United States: IRS suspends mailing of delinquent return-related notices to tax-exempt entities

25 Mar - Canada: Mutual agreement procedure (MAP) statistics for 2020

25 Mar - United States: Prior supervisory approval for penalty assessment for listed transaction; Tax Court reversed (Ninth Circuit)

24 Mar - Channel Islands: Updated FATCA and CRS practical guidance (Jersey)

24 Mar - Poland: Protocol to income tax treaty with the Netherlands scheduled to enter into force

24 Mar - South Africa: Third-party data annual submissions for AEOI; clarification of U.S. TIN data fields under FATCA

23 Mar - Brazil: Corporate income tax treatment of bonus, profit-sharing payments made to directors (court decision)

23 Mar - Mexico: Changes introduced by new transfer pricing regulations

23 Mar - Philippines: Guidance regarding responsibilities of banks in accepting tax returns and payments

23 Mar - United States: Federal district court vacates Notice 2016-66 (microcaptive insurance transactions)

22 Mar - United States: Penalties for erroneous claims for refund or credit (IRS practice unit)

22 Mar - Costa Rica: Customs inspection procedures

22 Mar - India: Diamond certification services not taxable technical services under treaty with United States (tribunal decision)

22 Mar - OECD: Public consultation on tax transparency framework for crypto-assets, proposed amendments to CRS

22 Mar - Thailand: Determining related parties when same group of shareholders involved

22 Mar - Australia: Tax treatment of digital assets and transactions; policy framework review

21 Mar - Australia: Consultation on proposed digital games tax offset

21 Mar - Nigeria: Transfer of interest in oil prospecting license subject to capital gains tax (tribunal decision)

21 Mar - UK: VAT incurred in selling shares may be recoverable (tribunal decision)

21 Mar - United States: California (acceleration of installment payments); Ohio (computer software); New York State (purchase for resale exemption)

21 Mar - United States: Initial determination of penalties, after IRS supervisory approval was obtained (U.S. Tax Court)

18 Mar - KPMG report: Updated analysis of Pillar Two model rules for 15% global minimum tax following release of commentary

18 Mar - Portugal: Taxation of dividends received by foreign UCITS contrary to EU law (CJEU judgment)

18 Mar - United States: IRS nonacquiescence to Eleventh Circuit’s decision, relocation benefits provided by railroad to employees

18 Mar - United States: Guidance related to conflict in Ukraine

17 Mar - Anguilla: FATCA, CRS reporting deadlines for 2021

17 Mar - EU: CJEU Advocate General opinions, EC and European Parliament updates

17 Mar - Germany: Updated CRS guidance

17 Mar - India: Permanent establishment under tax treaty with Japan; no withholding tax at source on share purchase

17 Mar - United States: Updated list of automatic changes (Rev. Proc. 2022-14)

17 Mar - United States: Proposed legislation would suspend normal trade relations with Russia and Belarus

16 Mar - United States: Compute foreign tax credit using same method that CFC used to apportion interest expense (U.S. Tax Court)

16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive

15 Mar - Bahrain: Economic substance information returns due 31 March 2022

15 Mar - EU: Further sanctions against Russia

15 Mar - United States: Sanctions against Russian and Belarusian individuals, entities

15 Mar - United States: Waiver of addition to tax under section 6654 for certain farmers, fishermen

14 Mar - United States: IRS TE/GE division provides new technical guides

14 Mar - United States: Regulations on charitable donation of conservation easement upheld as valid; Tax Court affirmed (Sixth Circuit)

14 Mar - Barbados: Deadline for pre-2021 FATCA and CRS reports extended to 15 April 2022

14 Mar - Bulgaria: Sale-leaseback agreements, transposition of EU directive, other corporate income tax measures

14 Mar - OECD: Commentary on Pillar Two model rules for domestic implementation of 15% global minimum tax

14 Mar - Saint Kitts and Nevis: Guidance on registering for FATCA and CRS reporting purposes

11 Mar - Canada: Clarification to reporting requirements for financial institutions under FATCA and CRS regimes

10 Mar - Poland: Limit on tax-deductible debt financing costs (court decision)

9 Mar - Singapore: Updated FATCA technical guidance and FAQs

9 Mar - India: Loss from permanent diminution in value of investment in U.S. subsidiary allowable as business expenditure (court decision)

8 Mar - Australia: Navigating stamp tax (duty) rules in 2022

8 Mar - KPMG report: Comments in response to EC public consultation on proposal for minimum tax directive

8 Mar - OECD: Comments on draft model rules for tax base determinations under Pillar One Amount A

8 Mar - United States: JCT releases “Bluebook” on tax legislation in 116th Congress

7 Mar - United States: California (unclaimed property); Iowa (corporate income tax rate reduction); Texas (taxable data processing services); Washington State (capital gains tax on individuals)

7 Mar - United States: New Russia-related FAQs released

7 Mar - Poland: VAT, tax relief measures related to conflict in Ukraine

7 Mar - Thailand: Revised transfer pricing disclosure form; country-by-country reporting notification and Q&As

4 Mar - Czech Republic: No revaluation of advances made in foreign currency toward fixed asset purchases (court decision)

4 Mar - KPMG report: Comments on OECD’s draft rules for tax base determinations under Pillar One
Amount A

4 Mar - Dominican Republic: Proposal to impose VAT on digital services provided from abroad

4 Mar - UK: Consultation concerning proposal for online sales tax 

4 Mar - UK: Notification requirement for uncertain income tax treatments regarding payroll

4 Mar - UK: “Ring fence” taxation of profits related oil production from continental shelf (Upper Tribunal decision)

4 Mar - United States: Additional sanctions against Russia, addition of entities to EAR entity list

3 Mar - United States: IRS failed to comply with notice-and-comment process in issuing Notice 2007-83 regarding “listed transactions" (Sixth Circuit)

3 Mar - United States: Rehearing en banc denied in subpart F income case (Sixth Circuit)

3 Mar - United States: Existing sanctions against Russia expanded under the Export Administration Regulations, targets oil refinery sector

3 Mar - United States: Russian “elites” and “intelligence-directed disinformation outlets" sanctioned

3 Mar - United States: Belarus sanctioned under the Export Administration Regulations

3 Mar - British Virgin Islands: Updates related to TINs for FATCA regime

3 Mar - Estonia: Amendments to transfer pricing regulation

2 Mar - Colombia: 2022 report on corporate compliance for legal entities with presence in Colombia

2 Mar - KPMG report: BEPS 2.0 issues and implications for Latin America

2 Mar - Saint Kitts and Nevis: Advisory on CRS requirement to obtain date of birth information

2 Mar - Sweden: Tax agency’s new rules for information reporting by certain foreign companies

1 Mar - Bulgaria: Withholding tax on “fictitious interest” assessed on interest-free loan (CJEU judgment)

1 Mar - EU: CJEU judgments, infringement procedures, and referrals; OECD updates

1 Mar - EU: Summary of sanctions concerning Russian persons and entities

1 Mar - Ireland: Updated CRS filing guidelines

28 Feb - United States: Cash-surrender value of life insurance policies not includible in estate (U.S. Tax Court)

28 Feb - United States: New York (cyber-protective services, sales tax); Pennsylvania (split-factor appointment); multiple states (federal tax conformity)

28 Feb - United States: OFAC sanctions prohibiting U.S. persons from engaging in transactions with certain Russian financial entities

28 Feb - United States: Regulations implementing executive order, Russia-related sanctions regulations

28 Feb - Bahamas: Updated EU “grey list” includes Bahamas and other Caribbean countries

28 Feb - Belgium: Tax authorities launch annual round of transfer pricing audits

28 Feb - KPMG report: Top concerns for tax leaders on the path forward for BEPS 2.0

28 Feb - OECD: Third batch of 2021/2022 updated transfer pricing country profiles

28 Feb - Poland: Transfer pricing documentation and financial transactions involving loans

28 Feb - Thailand: Multilateral instrument (MLI) is signed

25 Feb - Germany: Guidance on dual consolidated loss rule

25 Feb - Germany: Guidance on royalty deduction limitation rule; application to FDII

25 Feb - Germany: Status of income tax treaties

25 Feb - India: Support services fees not “fees for technical services” under tax treaty with Belgium (tribunal decision)

24 Feb - Brazil: Customs enhancements regarding physical controls and verification of goods

24 Feb - EU: Updates to list of non-cooperative jurisdictions

24 Feb - Philippines: Tax guidance from Bureau of Internal Revenue

24 Feb - Poland: Goodwill not subject to “capital duty” (court decision)

24 Feb - United States: Request for Section 1603 grants denied; facilities not placed in service in 2009 (Federal Circuit)

24 Feb - United States: Aditional sanctions against Russia under the Export Administration Regulations

24 Feb - United States: Sanctions imposed on transactions, trade with Russia

23 Feb - United States: Interest rates, tax underpayments and overpayments (increase for second quarter 2022)

23 Feb - United States: Professional basketball franchise not allowed deduction for deferred compensation when amounts not paid to players (U.S. Tax Court)

23 Feb - Italy: Luxembourg fund exempt from withholding tax on Italian dividends; refund opportunities (court decision)

23 Feb - Panama: Updated guidelines on electronic invoicing

23 Feb - UAE: Updated voluntary disclosure user guide for VAT and excise tax

22 Feb - OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A

22 Feb - KPMG report: Operational transfer pricing health check

22 Feb - Mexico: New guidelines for issuing electronic invoices

22 Feb - Thailand: Additional country-by-country reporting submission requirements

22 Feb - United States: Government’s comments opposing Canada’s digital services tax proposal

21 Feb - Italy: Spanish funds exempt from withholding tax on dividends from Italian companies; refund opportunity

21 Feb - Poland: VAT correction benefiting from bad-debt relief allowed (court decision)

21 Feb - Nigeria: Stock-in-trade not limited to raw materials for claiming input VAT (tribunal decision)

18 Feb - Nigeria: High Court nullifies levy imposed on companies to finance a police trust fund

18 Feb - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One

18 Feb - OECD: Draft rules for tax base determinations under Amount A of Pillar One; comments requested

17 Feb - KPMG report: Benefits of shared service centers in tax processes such as transfer pricing

17 Feb - South Africa: Draft interpretation note on intragroup loans, new transfer pricing guidance

17 Feb - India: Blocking of electronic credit ledger does not equal seizure of property (court decision)

17 Feb - India: Clarification of FAQs for U.S. reportable accounts under FATCA

17 Feb - India: No separate notification required, “most favoured nation” treaty clause (tribunal decision)

17 Feb - Italy: Guidance, details about “patent box” regime

16 Feb - Italy: Luxembourg fund exempt from withholding tax on dividends from Italian companies (court decision)

16 Feb - United States: IRS releases FAQs about relief for partnerships and S corporations preparing Schedules K-2 and K-3 for 2021

16 Feb - Australia: Proposal for “patent box” regime

16 Feb - British Virgin Islands: Annual fee for FATCA, CRS, and country-by-country reporting portal

16 Feb - Spain: Financing structure challenged, tax authorities look through Dutch entity to impose withholding tax on U.S. entity

16 Feb - Vietnam: Almost all tax treaties implicated with the signing of MLI

15 Feb - EU: CJEU judgments and referrals, infringement procedures, other developments

15 Feb - Australia: Managing cross-border intercompany financing arrangements (court case)

15 Feb - Botswana: Review of transfer pricing rules

15 Feb - Italy: Guidance concerning transfer pricing documentation, penalty protection regime

15 Feb - New Zealand: Public consultation on digitizing the tax system

14 Feb - Cayman Islands: Updated FATCA and CRS guidance

14 Feb - Cyprus: Protocols with Germany and Switzerland in effect

14 Feb - Poland: Grant of free-of-charge guarantee treated as “transaction” for transfer pricing purposes (court decision)

11 Feb - India: Interest paid on income tax refund held taxable under tax treaty with United States

11 Feb - Barbados: Rules requiring country-by-country reporting enacted

10 Feb - Italy: Changes to cooperative compliance regime

10 Feb - Spain: Penalties and sanctions imposed on failures to declare overseas assets (CJEU judgment)

9 Feb - Australia: Tax integrity bill would provide self-assessment of effective life of certain intangible assets

9 Feb - Netherlands: Tax inspector collective decision on Box 3 (wealth tax) class-action appeal

9 Feb - United States: IRS adds a new compliance campaign (LB&I division)

8 Feb - Canada: Proposals to limit interest deductions, require more disclosure and reporting

7 Feb - Czech Republic: Economic challenges potentially affecting transfer pricing

7 Feb - Japan: Extended filing, payment deadline for individual taxpayers; updated FAQs

7 Feb - Nigeria: New tax appellate rules for judicial proceedings

7 Feb - UAE: Transfer pricing implications with introduction of a corporate income tax regime

6 Feb - KPMG report: Public consultation document on Pillar One—draft model rules for nexus and revenue sourcing

4 Feb - Channel Islands: FATCA and CRS reporting deadlines extended to 31 March 2022 (Guernsey)

4 Feb - OECD: Public consultation on two-pillar solution launched; first building block under Pillar One released

4 Feb - United States: IRS nonacquiescence to Fifth Circuit’s decision; limitations period for backup withholding (AOD 2022-1)

4 Feb - United States: IRS revokes REIT private letter ruling

2 Feb - Nigeria: Transfer pricing outlook for 2022

1 Feb - Australia: Understanding the terms “exploration,” “use” and “first use” regarding asset depreciation (Full Federal Court decision)

1 Feb - EU: Summary of tax-related developments, actions from CJEU and European Commission

31 Jan - United States: List of automatic changes, accounting methods

31 Jan - United States: Constructive transfer of intangible property in reorganization (U.S. Tax Court)

31 Jan - Mexico: APAs no longer available for maquiladora companies

31 Jan - Mexico: Updated FATCA, CRS guidance 

31 Jan - UAE: Amendments to CRS regulations for Abu Dhabi Global Market

28 Jan - KPMG report: Transfer pricing documentation viewed as ongoing process, not a short-term project

28 Jan - Poland: National e-invoicing system effective 1 January 2022

27 Jan - Cyprus: FAQs on intra-group back-to-back financing transactions

26 Jan - United States: WTO decision in dispute with China over subsidy duties

26 Jan - Austria: Court decisions on goodwill depreciation and loss carryforwards; other developments

25 Jan - Costa Rica: Criteria used in selecting taxpayers for audit

25 Jan - India: A decade of the APA program; why it still makes sense

21 Jan - KPMG report: Implicit guarantees in transfer pricing

21 Jan - UK: Consultation on domestic implementation of Pillar Two rules

21 Jan - UK: Pillar Two concept of international shipping and boundaries of UK tonnage tax regime

21 Jan - UK: Updated HMRC guidance on notification of uncertain tax treatments

20 Jan - Montenegro: New transfer pricing rules

20 Jan - OECD: Transfer pricing guidelines for multinational enterprises and tax administrations

20 Jan - United States: FATCA responsible officer certifications due 1 July 2022

19 Jan - United States: Tax Court review of employment tax determinations under section 7436

19 Jan - EU: Report including CJEU judgment, European Commission and European Parliament developments

18 Jan - Germany: Updated CRS guidance

18 Jan - Poland: Individual ruling is not equal to APA (court decision)

18 Jan - Singapore: User guide to view or update AEOI profile

18 Jan - Switzerland: Implementation of Pillar Two global minimum tax

14 Jan - Barbados: Updated CRS and FATCA guidance

14 Jan - Croatia: Corporate profit tax interest rate on loans between related parties

14 Jan - Netherlands: Guidance on the Good Practices Tax Control Framework

14 Jan - United States: Pilot program, “fast-track processing” of letter ruling requests by corporate taxpayers

13 Jan - Bahrain: Country-by-country obligations extended to 28 February 2022

13 Jan - Canada: Tax relief from interest, penalties in Ontario

12 Jan - United States: National Taxpayer Advocate report to Congress identifying taxpayer challenges

12 Jan - Mauritius: Removal from EU list of “high-risk third countries”

12 Jan - Thailand: Extended deadlines for submitting country-by-country reports

11 Jan - Azerbaijan: Transfer pricing measures

11 Jan - Bolivia: Extension of deadlines regarding VAT documentation

11 Jan - UAE: Procedures for installment payments of penalties, administrative waiver of penalties

11 Jan - UK: Public consultation on implementation of Pillar Two

10 Jan - Albania: Anti-money laundering measures include rules regarding beneficial owners, enhanced due diligence measures

10 Jan - Argentina: Foreign exchange rules, guidance

10 Jan - Cambodia: Use of language, currency in accounting records and financial statements

10 Jan - India: Marketing services not fees for technical services; other developments

10 Jan - United States: Tax season starts 24 January 2022; most individual returns due 18 April 2022

7 Jan - United States: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers (Sixth Circuit)

7 Jan - Botswana: Tax amnesty extended through 30 June 2022

7 Jan - KPMG report: Common transfer pricing risks and opportunities of M&A transactions

6 Jan - Japan: Recordkeeping for electronic transactions; guidance for designated tax representative system

6 Jan - Japan: Updated FAQs under CRS regime

6 Jan - Mexico: Online digital tax receipt (CFDI), payroll tax

6 Jan - United States: IRS provides FAQs regarding research credit claims

6 Jan - United States: IRS TE/GE division releases summary of “FY 2021 accomplishments”

5 Jan - Channel Islands: FATCA and CRS guidance (Guernsey)

5 Jan - Cyprus: Income tax treaty with Jordan

5 Jan - Finland: Withholding tax refund awarded Luxembourg SICAV (court decision); possible refund opportunities

5 Jan - Nigeria: Country-by-country reporting requirements by branches and subsidiaries of foreign MNEs

5 Jan - Russia: CRS reporting format

4 Jan - Malta: Draft transfer pricing rules issued for public consultation

4 Jan - United States: Foreign tax credit and certain deductions of life insurance companies (final regulations)

4 Jan - United States: Overview of section 245A dividends received deduction (IRS practice unit)

4 Jan - United States: IRS modifies Hurricane Ida-related tax relief for taxpayers in six states

3 Jan - United States: IRS provides tax relief for taxpayers affected by Colorado wildfires

3 Jan - United States: Electronic submission required for Form 1024

3 Jan - Poland: Safe harbor rate of interest, related-party loans in 2022

31 Dec - United States: IRS releases annual revenue procedures for 2022

30 Dec - Malaysia: Voluntary disclosure program for indirect taxes opens in 2022

29 Dec - Mexico: Transition period for e-invoices with bill of lading component

29 Dec - Thailand: Measures to support e-tax invoices and e-receipts; relief from residential property transfer fees

23 Dec - EU: Proposed directive to neutralize misuse of shell entities for tax purposes

23 Dec - Poland: Protocol to tax treaty with the Netherlands

22 Dec - Canada: Details of proposed digital services tax (3%)

22 Dec - Cyprus: Country-by-country report for 2020 is due 31 January 2022

22 Dec - KPMG report: Initial analysis of Pillar Two model rules for global minimum tax under OECD/G20 Inclusive Framework

22 Dec - Malaysia: Taxpayer bank account information in garnishments

22 Dec - Thailand: Electronic signature requirements

22 Dec - United States: IRS extends Hurricane Ida tax relief to taxpayers in six states to 15 February 2022

22 Dec - United States: R&E changes from TCJA effective for tax years beginning after 31 December 2021

22 Dec - EU: Directive to implement Pillar Two is proposed

21 Dec - EU: Report of tax developments including actions in CJEU, EC, EU Council

21 Dec - Japan: Guidance addresses appointment of taxpayer representatives

21 Dec - United States: Competent authority arrangement concerning pension fund retirement schemes in Malta

21 Dec - OECD: Schedule for public consultations on two-pillar solution

20 Dec - OECD: Pillar Two model rules for domestic implementation of 15% global minimum tax

20 Dec - Australia-UK: Free trade agreement

20 Dec - Costa Rica: Tax incentives for film industry; tax audit plan for 2022

20 Dec - Sweden: “Expert” tax relief (court decision)

17 Dec - Cambodia: Tax treatment of credit-guarantee fees, activities

17 Dec - Germany: Updated CRS guidance

17 Dec - KPMG report: Uneven transfer pricing implications of pandemic

17 Dec - OECD: Forum’s discussion of tax administration issues, two-pillar solution, digital transformation

17 Dec - Australia: Independent parties would not have agreed to changes to financing arrangement (court decision)

16 Dec - Australia: Imported hybrid mismatch rule, final ATO guideline

16 Dec - Luxembourg and Ireland: Opinion of CJEU Advocate General regarding tax rulings issued to multinational entities

16 Dec - United States: Automatic consent to change methods of accounting (text of guidance)

14 Dec - KPMG report: Building an effective transfer pricing risk control framework

14 Dec - Mexico: Updated version for online digital tax receipts

14 Dec - Sweden: Current rules limiting deductions for intra-group interest payments held contrary to EU law (court judgment)

14 Dec - United States: IRS provides tax relief for taxpayers affected by tornadoes in Kentucky

14 Dec - United States: IRS releases five practice units, covering topics including BEAT and foreign tax credit

13 Dec - United States: Deadline extended once again—to April 15, 2023—for certain individuals with signature authority (FBAR filings)

12 Dec - United States: Senate Finance releases revised text of “Build Back Better Act”

11 Dec - United States: Preliminary text of Senate Finance’s portion of “Build Back Better Act”

10 Dec - Hungary: Considerations for year-end transfer pricing adjustments

9 Dec - Bermuda: Updated guidelines for CRS compliance certification form

9 Dec - Singapore: Updated FATCA and CRS guidance

9 Dec - Taiwan: Updated CRS regulations for “low-risk” financial accounts

8 Dec - EU: Code of Conduct, report to ECOFIN

8 Dec - EU: CJEU judgments and referrals, infringement procedures, other developments

7 Dec - United States: U.S. taxpayer realized subpart F income on sales of appliances manufactured in Mexico (Sixth Circuit)

7 Dec - Netherlands: VAT recovery based on bank’s “actual use method” (opinion of Advocate General to Supreme Court)

6 Dec - Canada: Updated XML schema, FATCA and CRS self-certification forms

6 Dec - Qatar: Preferential tax treatment requires compliance with economic substance regulations

6 Dec - UK: HMRC report on tax administration for large businesses

2 Dec - UK: Update on proposed changes regarding transfer pricing documentation

2 Dec - Portugal: Guidance concerning advance pricing agreements, transfer pricing documentation

2 Dec - Spain: MLI ratified, income tax treaties to be modified

1 Dec - United States: NOL limitation policy not supported by statute (Delaware) (court decision)

1 Dec - United States: Penalty for FBAR violation applies on per-account basis, not on per-form basis (Fifth Circuit)

1 Dec - United States and Turkey: Competent Authority Arrangement regarding exchange of country-by-country reports

1 Dec - Bahrain: Country-by-country notifications due 31 December 2021

1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal

1 Dec - Zambia: Transfer pricing measures included in 2022 budget

30 Nov - Nigeria: Extended deadline for waiver of interest and penalties on company tax liabilities

30 Nov - Belgium: New income tax treaty signed with France

30 Nov - Denmark: Changes to transfer pricing documentation requirements

30 Nov - Germany: Arm's length interest on intercompany loans (court decisions)

30 Nov - Japan: Overview of tax system

29 Nov - Japan: Updated FAQs under CRS regime

29 Nov - KPMG report: EU “public” country-by-country reporting and implications for multinational groups

26 Nov - KPMG report: Automating transfer pricing documentation

26 Nov - Australia: Transfer pricing and ATO report on “reportable tax position” schedule

24 Nov - Cyprus: DAC6 cross-border arrangements, reporting deadline again extended (31 January 2022)

24 Nov - United States and India: Agreement reached regarding “equalization levy” (digital services tax)

23 Nov - United States: Determining “immediate supervisor” for approving penalty when revenue agent has two different supervisors (U.S. Tax Court)

23 Nov - Canada: CRA to conduct audit to determine compliance with CRS and FATCA

23 Nov - EU: Infringement procedures and referrals to CJEU; European Parliament tax-related developments

23 Nov - UAE: Procedure for requesting penalty reconsideration

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2020

22 Nov - OECD: Peer review of automatic exchange of information (AEOI) published

22 Nov - UK: Transfer pricing items in HMRC annual report and accounts, 2020 to 2021

22 Nov - United States and Turkey announce digital services tax agreement

19 Nov - United States: House passes “Build Back Better Act” with tax measures

19 Nov - United States: Nonacquiescence to Eighth Circuit’s decision invalidating part of Reg. section 1.170A-9(c)(1), primary function of education organization (AOD 2021-4)

18 Nov - United States: IRA’s investment in coins, followed by taxpayer taking physical possession of the coins, held a taxable distribution (U.S. Tax Court)

18 Nov - KPMG report: Transfer pricing and factoring

18 Nov - Romania: Cancellation and reissuance of invoice, no implications for VAT refund period (CJEU judgment)

17 Nov - Chile: “Most favored nation” clause triggered under treaties with Canada and Mexico

17 Nov - Japan: Electronic recordkeeping requirements, performance-linked compensation measures under 2021 tax reform

17 Nov - South Africa: Penalties for individuals who fail to file tax returns

17 Nov - United States: IRS expands tax relief to all taxpayers in Mississippi affected by Hurricane Ida

17 Nov - United States: IRS updates “public key” for FATCA filing

16 Nov - United States: Inflation adjustments for information return penalties (Rev. Proc. 2021-45)

16 Nov - Switzerland: Considerations for transfer pricing year-end adjustments

15 Nov - Bermuda: Updated CRS compliance form guidelines

15 Nov - Colombia: Relief from interest and penalties for late payments of tax

15 Nov - Malta: Annual report for exchange of information under mandatory disclosure rules (DAC6)

15 Nov - United States: President signs bipartisan infrastructure bill, tax provisions are enacted

12 Nov - Romania: Standard audit file for tax, filing dates and implementation rules

12 Nov - India: Tax treatment of subscription fees for online databases and journals, tax treaty implications

12 Nov - Netherlands: Legislation addressing mismatches in application of arm’s length principle

11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting

11 Nov - KPMG report: Asia Pacific regional perspective on implementation of BEPS 2.0 as it relates to tax incentives

11 Nov - United States: “Build Back Better Act” tax proposals in pending House bill

10 Nov - EU: Developments from European Parliament, OECD and other international institutions

10 Nov - UAE: Clarification to tax procedure rules regarding taxpayer objections and appeals

9 Nov - Austria: Tax reform update; courts address treatment of reserved dividends, relief from double taxation; other developments

9 Nov - Singapore: Updated FAQs related to FATCA and CRS

9 Nov - United States: OFAC issues “finding of violation” to UAE bank regarding Sudan sanctions regulations

8 Nov - KPMG report: Managing multilateral controversy

8 Nov - Spain: Tax on increase in value of municipal land held unconstitutional (court decision)

5 Nov - United States: House passes bipartisan infrastructure bill with tax provisions, completing congressional action

5 Nov - Costa Rica: Local tax authorities to allow interest and penalty relief

4 Nov - Nigeria: Taxpayer’s deposit with FIRS found sufficient for tribunal’s jurisdiction

4 Nov - United States: JCT revenue estimate of tax provisions (as modified) in “Build Back Better Act”

3 Nov - United States: Expense allocation and apportionment in calculation of foreign tax credit limitation (IRS practice unit)

3 Nov - United States: IRS releases FAQs as reporting guidance for “carried interests”

3 Nov - Poland: Transfer pricing measures in “Polish Deal” legislation

2 Nov - Dominican Republic: Transfer pricing rules, updated compliance and documentation requirements

2 Nov - United States: Voluntary transfer pricing initiative in Louisiana

1 Nov - United States, EU agree to replace and suspend tariffs in steel and aluminum trade disputes

1 Nov - China: APA annual report provides statistics for 2020

1 Nov - Thailand: Automatic exchange of information (AEOI); actions by financial institutions expected beginning 2022

1 Nov - UAE: Tax procedural rules amended

29 Oct - EU: Combined Nomenclature for 2022

29 Oct - South Africa: Assessments after three-year limitations period expired (court decision)

29 Oct - Switzerland: VAT treatment of vouchers (court decision)

28 Oct - Poland: Penalties for payment delays in commercial transactions

28 Oct - Slovakia: Paperless communication system between tax authorities and taxpayers

28 Oct - United States: House Rules Committee releases updated version of the “Build Back Better Act” (initial impressions)

27 Oct - Bermuda: Updated guidelines, CRS compliance certification form

27 Oct - United States: Senate Finance Chairman Wyden unveils “billionaires income tax”

27 Oct - United States: IRS expands tax relief, certain taxpayers in Mississippi affected by Hurricane Ida

27 Oct - United States: U.S. trade or business, permanent establishment; nonresident employee education expenses (IRS practice units)

26 Oct - United States: Senate Finance Chairman Wyden introduces “corporate profits minimum tax”

26 Oct - Australia: Fuel tax credit; substantiation using GPS technology

26 Oct - EU: Summary of tax-related developments, actions from CJEU and European Commission

26 Oct - Germany: Guidance regarding interest on tax underpayments and overpayments

25 Oct - Cayman Islands: CRS compliance updates

22 Oct - Ireland: Transfer pricing measures included in Finance Bill 2021

22 Oct - Mauritius: Financial Action Task Force (FATF) list of jurisdictions for increased monitoring

22 Oct - UK: Revised HMRC approach to correcting CJRS errors

21 Oct - India: Refund claims of GST by “special economic zone” unit

21 Oct - United States: Treasury statement regarding digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

20 Oct - Australia: ATO guidance on preparing for GST assurance reviews

20 Oct - Bahrain: Updated guidance on mutual agreement procedures

20 Oct - Thailand: Transfer pricing requirements and country-by-country reporting, effective 2021

19 Oct - Australia: Status of legislation to implement a reporting regime for the "sharing economy"

19 Oct - Poland: Legislation requiring e-invoices by 2023

18 Oct - United States: Alaska (failure to file electronically); Oregon (sales factor and foreign dividends); Texas (apportionment); Texas (sales tax nexus)

18 Oct - United States: LB&I video-conferencing for large business taxpayers

18 Oct - United States: Treasury’s review of sanctions

18 Oct - Cyprus: Arrangement with United States for exchange of country-by-country reports

18 Oct - OECD: Status update on BEPS Action 13 (country-by-country reporting) and Action 14 (mutual agreement procedure)

18 Oct - Oman: VAT guide for “special zones”

15 Oct - Serbia: Changes to tax procedure, tax administration rules

15 Oct - Thailand: Digital tax coupons for use and application against customs duties and taxes

15 Oct - United States: IRS clarifies FAQs may offer reasonable cause for penalty protection, but are not precedential

15 Oct - United States: IRS sets forth required information for valid research credit claim for refund (Chief Counsel legal advice memo)

15 Oct - United States: Sanctions compliance guidance for virtual currency industry

14 Oct - Austria: Transfer pricing guidelines 2021 are finalized

14 Oct - India: Unused foreign tax credit; “fees for technical services” under Singapore tax treaty

14 Oct - Serbia: Updated transfer pricing guidance, information for country-by-country report

14 Oct - Vietnam: Guidelines on APA program changes

13 Oct - OECD: G20 finance leaders endorse changes to global tax rules

13 Oct - Australia: Proposed expansion of tax treaty network

13 Oct - Czech Republic: Arm’s length price, advertising as a deductible expense (court decision)

13 Oct - Czech Republic: Burden of proof, taxable and VAT-exempt services

13 Oct - France: VAT and mandatory e-invoicing; new effective date of 1 July 2024

11 Oct - EU: CJEU judgments and referrals, infringement procedures, other developments

11 Oct - Finland: Tax-exemption regime for investment funds, possible refund opportunity (CJEU Advocate General opinion)

11 Oct - Nigeria: Late-filing penalty and interest relief for companies, through 30 November 2021

11 Oct - UAE: User guide for appeals under economic substance regulations

11 Oct - UK: Closure notices for transfer pricing enquiries, despite ongoing diverted profits tax review (First-tier Tribunal)

8 Oct - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy

7 Oct - Nigeria: New procedural rules adopted for tax appellate tribunal

7 Oct - Saudi Arabia: Draft VAT legislation proposes changes for e-invoicing

7 Oct - Thailand: New requirements for transfer pricing and Local file documentation

7 Oct - United States: Form 1099-NEC added to the combined federal-state filing program

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

7 Oct - United States: IRS TE/GE compliance priorities, 2022 program letter

6 Oct - United States: FBAR filing deadline relief for persons affected by certain natural disasters

6 Oct - Czech Republic: Proposed implementation of directive for income earned by digital platforms (DAC7)

5 Oct - EU: Updates to list of non-cooperative jurisdictions

4 Oct - KPMG report: Country-by-country reporting, notification requirements per country

4 Oct - United States: Examining a reseller’s section 263A computation (IRS practice unit)

 

The Spring 2023 edition of Tax Dispute Resolution Quarterly features articles on:

• IRS current and future states
• Crypto crackdown on digital assets
• Administrative guidance on GloBE rules
• Pillar One’s Amount B
• EV charging raises state tax issues

Read the Spring 2023 Tax Dispute Resolution Quarterly