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Mark R. Martin

Principal in charge of WNT Tax Controversy & Dispute Resolution Services

KPMG in the U.S.


January 2023

31 Jan - Estonia: Company board member not liable for company’s VAT and income tax liabilities (Supreme Court decision)

31 Jan - Estonia: Country-by-country reporting and transfer pricing documentation deadlines

31 Jan - Ghana: Inauguration of Independent Tax Appeals Board

31 Jan - Serbia: New practice regarding collection of tax

30 Jan - Australia: Updated 2023 U.S. TIN reporting requirements under FATCA regime

30 Jan - Denmark: Beneficial ownership for purposes of withholding on dividends (Supreme Court decisions)

30 Jan - EU: European Commission public consultation on DAC7 implementing regulation

30 Jan - EU: Report on “Unshell” Directive proposal adopted by EU Parliament

30 Jan - Germany: Dividends received by partnership not eligible for exemption under EU Parent-Subsidiary Directive (tax court decision)

30 Jan - Germany: Taxpayer satisfied “motive test“ under CFC rules (lower tax court decision)

30 Jan - OECD: Comments on public consultation document on Amount B under Pillar One

30 Jan - Poland: Timing of income recognition with respect to overpaid taxes, income recognition from social security contributions (Supreme Administrative Court decisions)

30 Jan - Romania: Withholding tax on renumeration paid to non-resident service provider (CJEU Advocate General opinion)

30 Jan - Spain: Public consultation on changes to criteria for non-cooperative jurisdictions

30 Jan - United States: Illinois (amended return was timely filed); Texas (taxpayer may not amend franchise tax report); multistate (combined reporting)

27 Jan - United States: New rules and conditions for implementing alternative cost method for real estate developers

27 Jan - KPMG report: Comments on public consultation on new common corporate tax system in the EU (BEFIT)

27 Jan - Sweden: Penalties for omission of Form N9 relating to negative net interest income (Court of Appeal decisions)

26 Jan - United States: IRS annual revenue procedures for 2023

26 Jan - United States: Updated Technical Guide, excise taxes on self-dealing under section 4941

25 Jan - Cambodia: E-documents facility no longer available for monthly and annual tax on income declarations

25 Jan - KPMG report: Comments on public consultation document on Amount B under Pillar One

25 Jan - Netherlands: Guidance on rule to combat transfer pricing mismatches in context of capital contributions

25 Jan - Poland: Guidance on partnership merger, transformation (Supreme Administrative Court decisions)

24 Jan - United States: IRS provides tax relief for taxpayers in California affected by December storms, flooding, mudslides

24 Jan - Nigeria: Deadline for employer’s filing PAYE tax returns is 31 January 2023

24 Jan - OECD: New methodology for Action 14 peer reviews, changes to MAP statistics reporting and new APA statistics reporting

24 Jan - Philippines: Guidance concerning submission of inventory list and application of VAT to HMO plans of registered export enterprises

24 Jan - Poland: Deadline for follow-up withholding tax statement is 31 January 2023

24 Jan - United States: Form 1099-K delayed reporting thresholds

24 Jan - United States: State and local tax, technology-related developments (table, fourth quarter 2022)

23 Jan - Channel Islands: FATCA and CRS compliance program for 2023 (Jersey)

23 Jan - Finland: Reminder of FATCA and CRS annual information return submission deadlines

23 Jan - Hungary: Changes to transfer pricing rules, including reporting and documentation

23 Jan - KPMG report: Focus on country-by-country reporting (CbC) data with Pillar Two minimum tax and public CbC reporting

23 Jan - UK: Consultation on R&D tax relief reform

23 Jan - UK: Elements of nuclear decommissioning facility qualifying for plant and machinery allowances (Court of Appeal decision)

23 Jan - UK: Final mandatory disclosure rules (DAC6) regulations published

23 Jan - United States: Florida (sales tax refunds on software and hardware); Texas (margin tax apportionment); Virginia (NOL carryback)

20 Jan - United States: IRS extends due date for QI withholding agreement to 1 May 2023

20 Jan - United States: Permanent injunction against “tax mandate” in American Rescue Plan Act upheld (Eleventh Circuit)

20 Jan - Korea: Royalties subject to withholding under Korea-U.S. treaty (tax tribunal decision)

20 Jan - Mexico: Single self-determination system version 3.6.3

20 Jan - Uganda: Requirement to submit beneficial owners’ information

19 Jan - Cyprus: New single tax administration portal

19 Jan - Poland: Guidance on tax rulings (Supreme Administrative Court decisions)

19 Jan - South Africa: Interpretation note providing transfer pricing guidance on intragroup loans

19 Jan - United States: IRS provides tax relief for taxpayers in Georgia and Alabama affected by storms

18 Jan - United States: Changes in accounting methods (IRS practice units)

18 Jan - United States: Employers must file Forms W-2 and provide Forms 1099-NEC by 31 January 2023 (IRS reminder)

18 Jan - United States: Minnesota (federal tax conformity); Missouri (sales and use tax changes); Ohio (tax and fee amnesty); Washington State (bad debt sales tax credit and B&O tax deduction)

18 Jan - United States: SEC comments on accounting for income taxes

18 Jan - Botswana: Reduced VAT rate extended through 31 March 2023

18 Jan - Channel Islands: Annual tax reporting for partnerships (Jersey)

18 Jan - India: Exemption rule for educational institutions applies prospectively; beneficial owner of fees for technical services (court decisions)

17 Jan - United States: Export controls of certain advanced computing and semiconductor manufacturing items extended to Macau

17 Jan - Czech Republic: Application of thin capitalization test to interest paid on bonds (court decision)

17 Jan - Czech Republic: Guidance provided in Q&As on new reporting obligation under DAC7

17 Jan - Czech Republic: Referral to CJEU of issue relating to VAT exemption for supplies of goods to another member state when recipient is unknown

17 Jan - Greece: Instructions on procedure for adjustment of taxable profits following tax audit

17 Jan - India: Liaison office did not constitute PE; amalgamation plan rejected (court decisions)

17 Jan - Philippines: Monthly VAT declaration no longer required

13 Jan - Japan: FAQs on AEOI process for non-residents

13 Jan - Japan: Updated FAQs on AEOI reporting system under CRS regime

13 Jan - OECD: Manal Corwin appointed new Director of its Centre for Tax Policy and Administration

13 Jan - Slovakia: Changes to content of transfer pricing documentation

13 Jan - South Africa: Change in VAT treatment of “scrip-lending transactions”

13 Jan - United States: Amendments to EAR; controls on marine toxins, plant pathogens, biological equipment

12 Jan - United States: Annual inflation adjustment to civil monetary penalties

12 Jan - United States: Tax season starts 23 January 2023; most individual returns due 18 April 2023

12 Jan - Panama: Deadline for submitting 2021 country-by-country reports extended to 15 January 2023

11 Jan - EU: Update on DAC7 implementation

11 Jan - India: Withholding not required on estimated payments; application of beneficial treaty rate upheld (High Court decisions)

11 Jan - Poland: Changes to enforcement proceedings include recovery of VAT

11 Jan - Poland: Recent tax-related developments (court decisions)

11 Jan - Spain: Public country-by-country reporting implemented

11 Jan - Sweden: License fees paid to companies not performing DEMPE functions are not deductible (court decision)

11 Jan - United States: National Taxpayer Advocate report to Congress identifying taxpayer challenges, describing better outlook for 2023

10 Jan - United States: IRS provides tax relief for taxpayers in California affected by storms, flooding, mudslides

10 Jan - Bulgaria: Changes in VAT law, including reporting of data regarding cross-border payments

10 Jan - Kosovo: Introduction of tax procedures for application of income tax treaties

10 Jan - North Macedonia: Proposed changes to transfer pricing reporting

10 Jan - Singapore: Cement silo is not a “plant” for capital allowance purposes (court decision)

10 Jan - United States: House passes IRS defunding bill

10 Jan - United States: Jason Smith selected to chair House Ways and Means Committee

9 Jan - Canada: Importers subject to increased scrutiny regarding goods in supply chain

9 Jan - Panama: Period for satisfying some tax obligations is extended to 13 January 2023

9 Jan - UK: New guidance on “associated companies” test for determining applicable corporation tax rate and payment deadlines

9 Jan - UK: New transfer pricing documentation requirements, but delay of summary audit trail (SAT) pending public consultation

9 Jan - UK: “Time to pay” arrangements to help mitigate liquidity challenges

5 Jan - Germany: Updated CRS guidance

3 Jan - Poland: Corporate income tax exemption applied to total revenue from activities performed in special economic zones (court decision)

3 Jan - Montenegro: Arm’s length interest rate for 2023

3 Jan - Poland: Interest rates for transfer pricing purposes

3 Jan - Saudi Arabia: Second wave of e-invoicing applicability

3 Jan - Saudi Arabia: Zakat rules for investments in investment funds

1 Jan - United States: Analysis and observations on Rev. Procs. 2023-8 and 2023-11, guidance for accounting method changes under section 174

2022 Articles

December 2022

30 Dec - United States: Deadline for renewal of QI agreements covering 2023 through 2028

30 Dec - United States: IRS provides tax relief for taxpayers in New York affected by winter storm

30 Dec - United States: Notice of filing of petition for addition of polyphenylene sulfide to Superfund list

30 Dec - United States: Temporary relief for foreign financial institutions required to report U.S. TINs

29 Dec - Brazil: Draft legislation to align transfer pricing rules with OECD Transfer Pricing Guidelines

29 Dec - United States: Intention to propose regulations on requirements of clean vehicle credit under section 30D

29 Dec - United States: IRS provides FAQs on clean vehicle credits for new, previously owned and commercial vehicles

29 Dec - United States: Proposed regulations concerning electronically filed returns; OIRA review completed

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

29 Dec - United States: Standard mileage rates for 2023

29 Dec - United States: Treasury releases white paper on critical mineral and battery component requirements for clean vehicle tax credits

29 Dec - United States: Updated guidelines for accounting method changes for specified R&E expenditures

28 Dec - United States: IRS provides updated FAQs on Form 1099-K

27 Dec - United States: Interim guidance on new 1% excise tax on repurchases of corporate stock

27 Dec - United States: Interim guidance on new corporate alternative minimum tax (CAMT)

23 Dec - United States: Delay of implementation of $600 reporting threshold for Forms 1099-K

23 Dec - United States: Insurance companies, unpaid loss discount factors for 2022 accident year

23 Dec - United States: Transitional guidance for broker reporting on digital assets

22 Dec - Italy: Obligation to report information and withhold tax on short-term rentals upheld (CJEU judgment)

22 Dec - KPMG report: Public consultation document under Pillar One on draft multilateral convention provisions on DSTs

22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)

22 Dec - Latvia: Penalty for non-compliant transfer pricing documentation

22 Dec - Morocco: Temporary suspension of country-by-country report local filing requirement

22 Dec - Netherlands: 2023 Tax Plan adopted by upper house of Parliament, including DAC7, windfall profits tax on fossil sector

22 Dec - United States: IRS provides FAQs on energy efficient home improvements and residential clean energy property credits

22 Dec - United States: Senate passes Consolidated Appropriations Act (with revenue provisions)

21 Dec - United States: Guidance regarding withholding on transfers of publicly traded partnership interests

21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis

21 Dec - Serbia: Changes to tax procedure and administration law

20 Dec - Canada: Updated FATCA and CRS self-certification forms

20 Dec - Hong Kong: Upfront lump-sum spectrum license fees must be capitalized (court decision)

20 Dec - OECD: Public consultation documents on withdrawal of DSTs under Pillar One, implementation under Pillar Two

20 Dec - Philippines: Temporary suspension of field audits and operations

20 Dec - UAE: New transfer pricing rules

19 Dec - Serbia: Rulebook on arm’s length interest rates for 2022

19 Dec - UK: HMRC guidance on redaction of information under AEOI on human rights ground

19 Dec - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Nicole

19 Dec - United States: Treasury timeline for providing guidance on “Inflation Reduction Act” tax provisions

16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax

16 Dec - EU: Council adopts EU minimum tax directive

16 Dec - Belgium: New obligations of digital platform operators (DAC7)

16 Dec - Korea: Tax authority’s determination of arm’s length price upheld (Tax Tribunal decision)

15 Dec - Korea: Liquidated damages for non-fulfillment of minimum purchase quantity included in price of imported goods

15 Dec - Hungary: Guidance on transfer pricing reporting

15 Dec - Mexico: Limitation on deductibility of net interest held valid (court decision)

15 Dec - Saudi Arabia: Penalty waiver for all taxes, including VAT and excise tax extended until May 2023

14 Dec - EU: Proposal to extend tax transparency rules to cryptoassets

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

13 Dec - Poland: Application of general anti-avoidance clause (GAAR)

13 Dec - Czech Republic: Taxpayer entitled to deduct VAT on supply within fraudulent transactions chain (Supreme Administrative Court decision)

13 Dec - Czech Republic: Tax loss from transfer pricing adjustments abroad denied (court decision)

13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)

13 Dec - EU: VAT gap statistics for 2020

13 Dec - India: Set-off of loss against foreign dividend income; revaluation of partnership assets taxable; fixed and agency permanent establishment

13 Dec - Poland: Amendments to decrees on transfer pricing reporting

13 Dec - United States: Consideration of tax consequences in determining arm’s length result (GLAM)

12 Dec - United States: Automatic changes to accounting methods to comply with section 174

12 Dec - United States: Procedures for manufacturers and sellers of clean vehicles to qualify for tax incentives

12 Dec - UAE: Implementation of new federal corporate income tax system, related transfer pricing rules

12 Dec - KPMG report: U.S. administrative law basics for transfer pricing professionals

9 Dec - KPMG report: Public consultation on Amount B under Pillar One

9 Dec - Slovakia: Public country-by-country reporting implemented

9 Dec - UK: HMRC response to consultation on basis period reform issues

9 Dec - UK: Income tax treaty with Brazil signed

9 Dec - UK: Report of national audit office on operation and implementation of digital services tax

9 Dec - United States: Extended deadline is 15 April 2024, for individuals with signature authority (FBAR filings)

9 Dec - EU: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid under EU law (CJEU judgment)

8 Dec - EU: European Commission proposes new tax transparency rules for service providers facilitating cryptoasset transactions

8 Dec - Germany: Ownership of majority voting rights as requirement to form VAT fiscal unity (CJEU judgment)

8 Dec - United States: Special enforcement matters, centralized partnership audit regime (final regulations)

7 Dec - United States and Croatia sign income tax treaty

7 Dec - United States: MAP and the exhaustion of remedies for FTC purposes

7 Dec - Estonia: Recent tax-related developments, including reporting obligations for digital platform operators (DAC7)

7 Dec - Kenya: Minimum tax on gross turnover is unconstitutional (court decision)

6 Dec - Philippines: Guidance regarding payment of penalties for violations of permitted scope of work-from-home arrangements for certain registered business enterprises

6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda

6 Dec - Israel: Tax authority’s intangible property valuation upheld due to insufficient and inconsistent taxpayer documentation (court decision)

6 Dec - Kenya: Apple concentrate for cider subject to 10% duty rate (court decision)

6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed

6 Dec - KPMG report: OECD official provides update on work on Amount B

6 Dec - Romania: Public country-by-country reporting implemented

6 Dec - United States: Certain syndicated conservation easement transactions identified as listed transactions (text of regulations)

5 Dec - Belgium: Reform of periodic VAT returns, debts

5 Dec - Italy: Update on withholding tax on dividends paid to investment funds and related refund opportunities

5 Dec - Nigeria: One-month waiver of penalties and interest on certain tax liabilities

5 Dec - Vietnam: Tax obligations for enterprises creating and using science and technology development fund

2 Dec - United States: IRS provides tax relief for certain taxpayers affected by snowstorm in New York

1 Dec - Belgium: Assessment periods for income tax and VAT extended

1 Dec - Finland: Clarifications on DAC7 reporting obligations

1 Dec - Vietnam: Tax administration rules for e-commerce business activities of family businesses and individuals

November 2022

30 Nov - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

30 Nov - Germany: No exit tax resulting from amendment of income tax treaty (fiscal court decision)

30 Nov - Italy: New rules on import VAT recovery

30 Nov - KPMG report: Transfer pricing in the soccer field

30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced

30 Nov - Poland: Royalty payments to beneficial owner outside EEA not eligible for withholding tax exemption (court decision)

29 Nov - United States: 90-day time limit to file deficiency petition is jurisdictional deadline not subject to equitable tolling (U.S. Tax Court)

29 Nov - United States: Interest rates, tax underpayments and overpayments (increase for first quarter 2023)

29 Nov - Belgium: Interest on foreign regulated savings deposits exempt from individual income tax (court decision)

29 Nov - India: Capital gain not taxable under old India-Mauritius treaty (tribunal decision)

29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics

29 Nov - Netherlands: Floating solar park not considered immovable property subject to VAT (court decision)

28 Nov - China: Advance pricing arrangement annual report for 2021

28 Nov - EU: Anti-money laundering measure allowing access to beneficial ownership information held invalid (CJEU judgment)

28 Nov - Panama: “Extraordinary payment agreements” for tax obligations

28 Nov - Qatar: Transfer pricing documentation requirements

28 Nov - UK: Advisor fees related to potential disposal of subsidiary treated as non-deductible capital expenses (Court of Appeal decision)

22 Nov - EU: Public country-by-country reporting implementation summary

22 Nov - Malta: Formal transfer pricing rules published

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021

22 Nov - Poland: Ratification of treaty with Georgia; MCAA for automatic information exchange under digital platform reporting rules signed

22 Nov - Poland: Recent VAT-related developments (court decisions)

22 Nov - Qatar: Refund of excise tax paid to goods

22 Nov - United States: Rehearing en banc denied in section 965 case (Ninth Circuit)

21 Nov - United States: Colorado (federal retroactive changes applied; includible corporation in unitary combined group); Wisconsin (unclaimed property voluntary disclosure program); Wyoming (roadside services not subject to excise tax)

18 Nov - Costa Rica: Deadline for filing informative tax returns of dormant companies extended to 30 April 2023

18 Nov - Korea: Transfer pricing adjustments with respect to subsidiary loan and subsidiary performance guarantees affirmed (High Court decision)

18 Nov - United States: Guidance relating to the foreign tax credit (text of regulations)

17 Nov - United States: IRS provides tax relief for certain taxpayers affected by storm and flooding in Illinois

17 Nov - Germany: Updated guidance on application of arm’s length principle to cross-border transfers of functions

17 Nov - India: Capitation fees received by educational institution not eligible for exemption available to a charitable trust (court decision)

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

17 Nov - South Africa: Proposed withdrawal of practice allowing deduction of interest expense against related interest income

16 Nov - Austria: Changes to reclaim procedure for withholding taxes on dividend distributions

16 Nov - Belgium: Amendments to VAT statute of limitations, retention period and applicable interest rates

16 Nov - Denmark: DAC7 guidance

16 Nov - United States: Procedures for eligible taxpayers to file qualified amended returns

16 Nov - United States: Year-end tax discussion ideas for international tax and transfer pricing

15 Nov - Hungary: Proposed amendments to advance pricing arrangement rules and introduction of public country-by-country (CbC) reporting

15 Nov - Mexico: Increase to state taxes on remuneration for subordinate personal work and drinking water (Baja California state)

15 Nov - Netherlands: VAT recovery based on bank’s “actual use method” (Supreme Court decision)

15 Nov - United States: KPMG comments on proposed regulations providing guidance on IRS Independent Office of Appeals

14 Nov - Italy: Intermediate holding companies in private equity structures served genuine, non-tax purpose (court decisions)

14 Nov - Montenegro: Guidance under new transfer pricing rules

14 Nov - Panama: Benefits granted under “SEM Visa” not unconstitutional (Supreme Court decision)

14 Nov - United States: Georgia (“safe rides fee” subject to sales and use tax); Wisconsin (guidance on taxation of NFTs); multistate (income tax changes approved on election day)

14 Nov - United States: Fair value analysis under satellite radio sourcing rules for franchise tax purposes (Texas appeals court decision)

11 Nov - Bolivia: Fourth group of taxpayers required to issue tax documents through online billing modality

11 Nov - KPMG report: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

11 Nov - Nigeria: Taxation of institutions offering non-interest financial products and services in Nigeria

11 Nov - UK: Implications of interest rate increases for transfer pricing

10 Nov - Czech Republic: Penalty for filing VAT ledger statement for incorrect taxable period struck down (Supreme Administrative Court decision)

10 Nov - Netherlands: Concept of “essentially a new building” for VAT purposes (Supreme Court decision)

10 Nov - OECD: Jurisdictions sign MCAA for automatic information exchange under digital platform reporting rules, CRS disclosure rules

10 Nov - United States: President Biden to nominate Daniel Werfel as IRS Commissioner

9 Nov - United States: Listing notice is legislative rule improperly issued under the Administrative Procedure Act (U.S. Tax Court)

9 Nov - Poland: Cashback discounts do not reduce output tax; correcting invoice does not reduce taxable base (administrative court decisions)

9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)

8 Nov - Belgium: Retroactive application to 2016 of annual tax on credit institutions struck down (Constitutional Court decision)

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

8 Nov - Philippines: Guidance on electronic filing email notification

7 Nov - United States: Missouri (club membership dues subject to sales tax); Oregon (market-based sourcing); Wisconsin (manufacturing credit); multiple states (escheatment rules)

7 Nov - United States: Program for approving 403(b) retirement plans (Rev. Proc. 2022-40)

7 Nov - Mexico: Electronic invoice 4.0 (CFDI 4.0) mandatory beginning 1 April 2023 (three-month extension)

4 Nov - Vietnam: Guidance on various tax-related rules, including e-commerce information reporting

3 Nov - Austria: Inflation relief-related tax measures, DAC7 implementation, guidance on crypto taxation, updated VAT guidelines, other tax developments

3 Nov - FinlandDraft legislation to implement DAC7

3 Nov - Germany: Draft legislation to implement public country-by-country reporting; update on Pillar Two implementation

3 Nov - Hungary: Draft legislation to implement public country-by-country reporting

3 Nov - Netherlands: Dynamic interpretation of tax treaties (Supreme Court decision)

3 Nov - Spain: Dynamic interpretation of tax treaties (Supreme Court decision)

3 Nov - United States: Additional requests for comments on upcoming clean energy tax guidance (IRS notices)

2 Nov - Bahrain: Updated list of goods subject to excise tax

2 Nov - Saudi Arabia: Application of Zakat regulations

2 Nov - United States: CBP announces change to fees for duty-free treatment of infant formula, possible refund opportunities

1 Nov - Hong Kong: Procedure for complying with economic substance requirements under foreign-sourced income exemption regime

1 Nov - Poland: Government approves extension of excise tax exemption for plug-in electric vehicles

1 Nov - Poland: Recent tax developments related to debt for equity swaps, deductibility of team-building event costs (Supreme Administrative Court decisions)

October 2022

31 Oct - Belgium: Tax on securities accounts upheld, but certain anti-abuse measures struck down (Constitutional Court decision)

31 Oct - Singapore: Updates to e-tax guide on R&D tax measures and claim form

31 Oct - UAE: Amended VAT law provisions; new article related to statute of limitations

31 Oct - United States: Combined federal state filing program

31 Oct - United States: Pennsylvania (sourcing of digital audio book sales); South Carolina (fees subject to sales and use tax); Washington State (sourcing of patent procurement services income)

28 Oct - United States: O’Donnell appointed IRS “Acting Commissioner”

28 Oct - Lithuania: Right to charge VAT on sale of immovable property to VAT payer (CJEU judgment)

28 Oct - Netherlands: Proposed legislation implementing cross-border payment reporting obligation beginning 2024

28 Oct - UK: HMRC guidance regarding enterprise management incentives options 

27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget

27 Oct - Germany: Taxpayer may benefit from preferential treatment under any applicable income tax treaty (tax court decision)

27 Oct - Germany: Trade tax treatment of dividend from dual resident corporation (tax court decision)

26 Oct - United States: DOJ will not seek U.S. Supreme Court review of case concerning crude oil tax imposed by section 4611(b)

26 Oct - Qatar: Guidance on submission of no-objection certificate

25 Oct - Belgium: Limitation on dividends received deduction surpluses carried over to absorbing company compatible with EU law (CJEU judgment)

25 Oct - Poland: Updated transfer pricing reporting obligations guidebook

24 Oct - Poland: Transfer pricing measures in legislation amending “Polish Deal”

24 Oct - Uganda: Adjustment of PAYE return for secondary employment income

24 Oct - United States: Illinois (guidance on taxation of cryptocurrency), Maryland (digital advertising tax struck down), multiple states (tax rate changes on ballots)

21 Oct - Costa Rica: Action challenging principle of territoriality as unconstitutional dismissed (court decision)

21 Oct - India: Doctrine of promissory estoppel cannot be invoked against legislative action (Supreme Court decision)

21 Oct - India: Equalization levy could not be imposed on online advertising charges (tribunal decision)

21 Oct - United States: Examination of extended statute of limitations under section 965

20 Oct - Cyprus: Clarification on bilateral Competent Authority Arrangement for exchange of CbC reports with United States

20 Oct - Germany: Penalties for failure to comply with the obligation to keep or provide transfer pricing documentation compatible with EU law (CJEU judgment)

20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive

20 Oct - South Africa: Guidance on definition of “associated enterprises” under transfer pricing rules

19 Oct - India: GST common portal opening extended to file or revise Forms TRAN-1 and TRAN-2 (Supreme Court decision)

19 Oct - India: Six-month extension of Foreign Trade Policy 2015-2020; other trade and customs-related developments

19 Oct - United States: Deadline to file 2019 and 2020 tax returns to get penalty relief postponed in declared disaster areas (IRS reminder)

18 Oct - United States: “Report of Foreign Bank and Financial Accounts” (FBAR)

18 Oct - Bahrain: Preparing for VAT field audits

18 Oct - Korea: Criteria for determining beneficial owner under Austria treaty (tax tribunal decision)

18 Oct - Korea: Transfer pricing adjustments added to customs value of imported goods when directly related (Supreme Court decision)

17 Oct - United States: Mississippi (digital photography service); Tennessee (sales of subscriptions to electronic publications); Texas (web-based weather forecasting service); multiple states (nexus)

17 Oct - Hong Kong: Taxpayers entitled to refund of excessive tax reserve certificates purchased plus interest (court decision)

17 Oct - Poland: Services provided by securitization fund to bank/investment fund qualified as “granting of credit” for VAT purposes (CJEU judgment)

17 Oct - South Africa: MLI to enter into force 1 January 2023

14 Oct - Australia: New income tax treaty with Iceland signed, incorporating BEPS recommendations

14 Oct - KPMG report: Current state and trends in transfer pricing for intercompany financial transactions

14 Oct - OECD: Updated guidance on implementation of country-by-country reporting

13 Oct - United States: Partnership distribution of “clients” was distribution of intangible assets (U.S. Tax Court)

12 Oct - United States: Calendar year corporate income tax return filing deadline extended to November 15, 2022 (Illinois)

12 Oct - United States: IRS updates FAQs on QI / WP / WT website, certifications and periodic reviews

12 Oct - Bahrain: Updated VAT registration guideline; new decision for digital stamp scheme

12 Oct - KPMG report: Transfer pricing considerations in the age of precision medicine

11 Oct - Lithuania: Supply recipient may deduct VAT even though supplier did not pay output VAT (CJEU judgment)

11 Oct - Nigeria: VAT is principal tax on goods and services in hotels, restaurants and event centers (court decision)

11 Oct -  United States: Additional permitted election changes for health coverage under “cafeteria plans”

11 Oct - United States: IRS expands penalty relief for dyed diesel fuel in Florida; hurricane-related relief

11 Oct - United States: Taxpayer assistance procedures for S corporations under section 1362(f)

10 Oct - United States: Colorado (streaming platform credits); New York (nontaxable information services); Oregon (business license tax law); South Dakota (bank franchise tax)

10 Oct - United States: Penalties on unified annual reconciliation of apportionable income (Washington State)

10 Oct - India: Appellant can pay 10% of disputed tax using either electronic cash or credit ledger (high court decision)

7 Oct - United States: Extended temporary relief, low-income housing credit under section 42 (Notice 2022-52)

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

5 Oct - United States: Requests for comments on upcoming clean energy tax guidance (IRS notices)

5 Oct - United States: IRS provides tax relief for taxpayers affected by Hurricane Ian (North Carolina and South Carolina)

5 Oct - Australia: ATO guide on tax reporting of cryptoassets

4 Oct - Germany: Disallowance of final losses incurred by UK permanent establishment upheld (CJEU judgment)

4 Oct - Philippines: Guidelines and procedures for requesting MAP

3 Oct - Mexico: Procedures for employer to obtain opinion on compliance with social security tax obligations

3 Oct - Poland: Recent tax developments relating to holding structure, deduction cap for intangible services (Supreme Administrative Court decision)

3 Oct - United States: Colorado (retail delivery fee guidance); Iowa (corporate income tax rate reduction); Texas (R&D credit); West Virginia (tax preparer must collect sales tax)

3 Oct - United States: IRS announces new sign-in system for QI / WP / WT application and account management system (QAAMS)

September 2022

30 Sep - Belgium: Guidance on VAT refund procedures and remunerations in football

30 Sep - Portugal: EU General Court upholds EC’s determination that tax benefits in Madeira free zone not correctly applied

30 Sep - Slovakia: Proposed changes to transfer pricing rules and limitations on deductibility of interest

30 Sep - United States: IRS to waive dyed diesel fuel penalty in Florida; hurricane-related relief

29 Sep - Canada: Increased audit activity related to annual federal 10% excise tax on cross-border insurance premiums

29 Sep - Canada: Changes to customs importer of record rules, implications for e-commerce importers

29 Sep - Italy: Swiss social security institute entitled to withholding tax refund; possible refund opportunities (Supreme Court decision)

29 Sep - Puerto Rico: Tax-related hurricane relief

29 Sep - South Africa: Increased transfer pricing scrutiny

29 Sep - Spain: Challenge to Spanish tax leasing system (CJEU Advocate General opinion)

29 Sep - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Ian

28 Sep - Bahrain: Access to taxpayer "relationship manager" details

28 Sep - Belgium: Deadline for filing Local file forms is 17 October 2022

28 Sep - Germany: Draft legislation on implementation of DAC7 and modernization of tax procedures law

28 Sep - Germany: Draft legislation on submission of transfer pricing documentation in tax audit

28 Sep - Germany: Withholding tax exemption denied (lower tax court decision)

28 Sep - Switzerland: Tax-related information exchange with Russia suspended, including country-by-country (CbC) reports

27 Sep - Hong Kong: Procedure for confirming economic substance under revised exemption regime

27 Sep - Philippines: Electronic filing, filing of returns, payment of taxes extended

27 Sep - United States: IRS provides tax relief for certain taxpayers affected by storms in Alaska

26 Sep - Malaysia: Extension of payment period under second phase of voluntary disclosure program for indirect taxes

26 Sep - United States: Colorado (cryptocurrency as payment for taxes); Illinois (abatement of late penalties); Louisiana (manufacturing allocation formula)

26 Sep - United States: Excess loss account included in income of consolidated group member (U.S. Tax Court)

26 Sep - United States: Extension of time to amend certain eligible retirement plans for qualifying distributions

26 Sep - United States: LB&I memo providing updated guidance on the statute of limitations with respect to section 965 examinations

22 Sep - Canada: Pension plan contributions and employment insurance apply to restaurant tips (court decision)

22 Sep - Finland: Withholding tax refunds for Luxembourg SICAV funds

21 Sep - Bahrain: Deadline for ultimate parent entity of MNE resident in Bahrain to file country-by-country (CbC) report

19 Sep - Belgium: DAC6 legislation held invalid, questions raised to CJEU (Constitutional Court decision)

19 Sep - India: Guidance regarding withholding on benefits arising from recipient’s business or profession

19 Sep - Korea: Arm’s length interest rate on late-paid trade receivables; use of APA application information (Tax Tribunal decisions)

19 Sep - Korea: Preferential tariff rate under Korea-ASEAN free trade agreement; customs value based on fallback method (Tax Tribunal decisions)

19 Sep - UK: Increased HMRC scrutiny of R&D claims

19 Sep - United States: IRS provides tax relief for taxpayers in Puerto Rico affected by Hurricane Fiona

19 Sep - United States: “Qualified disaster” declaration allowing employer-sponsored charities to provide relief (Puerto Rico)

19 Sep - United States: IRS updates information on pre-screening and certification process of Work Opportunity Tax Credit (WOTC)

19 Sep - United States: Updated Technical Guide on exemption of certain business leagues and boards

19 Sep - United States: Sales and use tax manufacturing exemption (Missouri), service contract subject to sales and use tax (North Carolina), sales and use tax collection by out-of-state sellers (Pennsylvania), bookstore membership fees subject to sales and use tax (South Carolina)

16 Sep - United Kingdom: Anti-treaty shopping rule under Irish treaty did not apply to deny withholding tax relief on interest income (court decision)

16 Sep - United States: Unclaimed property voluntary compliance program legislation enacted (California)

15 Sep - Gibraltar: Rule preventing double taxation of amounts recovered as unlawful state aid may be applied (CJEU judgment)

15 Sep - Luxembourg: Increased scrutiny on FATCA and CRS compliance

15 Sep - United States: IRS opens application period for 2023 Compliance Assurance Process (CAP) program

15 Sep - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU Advocate General opinion)

14 Sep - UK: Taxation of cross-border intragroup asset transfer not contrary to EU law (CJEU Advocate General opinion) 

14 Sep - Germany: Holding company has no right to recover VAT on services contributed to subsidiary (CJEU judgment)

13 Sep - Czech Republic: Proposed record keeping and reporting obligation for payment service providers beginning 2024

12 Sep - Spain: Deadline to claim VAT refunds for 2021 is 30 September 2022

9 Sep - India: Application of “most favoured nation” clause under treaty with the Netherlands (tribunal decision)

9 Sep - United States: Guidance relating to IRS Independent Office of Appeals (text of proposed regulations)

6 Sep - Mexico: Proposed seventh modification to miscellaneous tax resolution 2022, changes to tax-related penalties

6 Sep - Poland: Recent tax developments relating to company reorganizations, lump-sum income tax, e-signing returns

6 Sep - South Africa: Tax authority to issue letters requesting specific corporate documents; supplementary declaration forms (IT14SD) discontinued

6 Sep - UK: Updated HMRC guidance on making tax digital for income tax self-assessment

2 Sep - Cyprus: Non-deductible input VAT on acquisition of apartment under Cypriot Investment Program (tribunal decision)

2 Sep - United States: IRS provides tax relief for taxpayers affected by water crisis (Mississippi)

1 Sep - Denmark: Reminder of 6 September deadline for transfer pricing documentation

1 Sep - Philippines: Guidance on lifting suspension of field audit and operations

August 2022

30 Aug - United States: Rules for determining stock ownership under section 958

30 Aug - Malta: Record keeping and reporting obligations for payment service providers beginning 2024

30 Aug - Mexico: Transfer pricing documentation for derivative financial transactions

29 Aug - Poland: Recent tax developments relating to robotization (Supreme Administrative Court decision)

29 Aug - Poland: Transfer pricing measures in draft bill

26 Aug - Bulgaria: MLI ratified

26 Aug - EU: Taxation-based obstacles and distortions in cross-border investment; regulation of intermediaries in the EU (European Parliament)

26 Aug - Finland: Mandatory disclosure rules (DAC6) reporting assessment published

26 Aug - OECD: Peer review reports on transparency and exchange of information on request

26 Aug - Slovenia: Public consultation on implementation of directive for income earned by digital platforms (DAC7)

26 Aug - Switzerland: Public consultation on draft ordinance regulating minimum taxation in Switzerland (Pillar Two)

25 Aug - Australia: Entities paying notional GST have rights of appeal in federal courts (Federal Court decision)

25 Aug - Finland: Updated FATCA and CRS FAQs

25 Aug - Luxembourg: Penalties related to real estate levy reporting obligation assessed

25 Aug - Nigeria: Reminder of 31 August 2022 deadline for filing companies income tax returns for 2022

25 Aug - OECD: Comments on progress report on Amount A of Pillar One

25 Aug - United States: Partnership’s payments to lender were deductible interest, and not payments on an equity interest (U.S. Tax Court)

25 Aug - United States: Sixth Circuit affirms Tax Court decision that taxpayer not liable for 40% penalty upon cancellation of APAs

24 Aug - United States: Penalty relief for certain taxpayers filing returns for tax years 2019 and 2020

24 Aug - United States: Early distribution 10% exaction is tax, not a penalty requiring written supervisory approval; Tax Court affirmed (Second Circuit)

24 Aug - Germany: Law amending interest on back taxes and tax refunds effective 22 July 2022

24 Aug - Germany: Real property management company premises can be permanent establishment of contracting company (tax court decision)

24 Aug - Ireland: Updated reporting entity registration form for FATCA, CRS purposes

24 Aug - Mexico: Penalties and sanctions do not apply to noncompliant electronic invoices with consignment note complement

23 Aug - KPMG report: Implementation of ATAD I and II by EU Member States

23 Aug - Philippines: New letter of authority must be issued if tax investigation reassigned

23 Aug - Vietnam: FATCA FAQs for 2021-2022 reporting

22 Aug - Poland: Deductibility of expenses incurred on behalf of third party; required information for individual ruling (court decisions)

18 Aug - United States: Tax Court’s determination of transfer pricing method, on remand from Eighth Circuit

18 Aug - United States: IRS Appeals invites input on enhancing video conferences

17 Aug - Canada: Mandatory disclosure rules proposed to apply beginning 2023

17 Aug - Canada: Possible changes to general anti-avoidance rule (GAAR), comments due 30 September 2022

16 Aug - UAE: New service for voluntary disclosure of errors on customs declarations

15 Aug - Costa Rica: Extension of deadline for filing dormant entities tax returns

15 Aug - United States: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2022)

12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information

12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes

11 Aug - EU countries: Transposition of EU directive, cross-border distributions of collective investment undertakings

11 Aug - Nigeria: No retroactive application of tax law changes unless expressly stated (court decision)

11 Aug - Hong Kong: Company directors not liable for additional taxes for incorrect profits tax returns filed by company (court decision)

10 Aug - Hong Kong: Income tax treaties to be modified by MLI

10 Aug - British Virgin Islands: Amendments to FATCA and CRS legislation

10 Aug - Italy: Tax audits based on cross-border transactions, transfer pricing issues

10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures

9 Aug - Czech Republic: Guidance provided in Q&As on cross-border arrangement reporting under DAC6

9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance

9 Aug - Poland: Tax authority’s access to banking information of taxpayers subject to proceedings

9 Aug - United States: JCT revenue estimates and distributional analysis of budget reconciliation bill

9 Aug - United States: Legislative text of reconciliation bill with tax provisions

8 Aug - Hong Kong: Salaries tax treatment of share award; vesting vs. forfeiture (court decision)

8 Aug - Panama: Extension for updates to taxpayer registry, due 31 August 2022

8 Aug - UK: Commercial transaction structured in tax-efficient way did not have “main purpose” of tax avoidance (court decision)

8 Aug - UK: Deduction of interest on intragroup loan used for third-party acquisition disallowed (court decision)

8 Aug - UK: HMRC “claw back” of coronavirus job retention scheme (CJRS) grants for noncompliance (court decision)

5 Aug - Austria: Implementation of DAC7 and reporting requirements for digital platform operators

5 Aug - South Africa: Tax authority targets e-service suppliers and VAT compliance

5 Aug - United States: Partnership upheld as valid, despite IRS claims it never would have been profitable without refined-coal tax credits (D.C. Circuit)

5 Aug - United States: Deductions denied for deferred cash payments of $51 million made to former spouse (Eighth Circuit)

5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency

4 Aug - Australia: Proposal to require reporting by digital platforms

4 Aug - Philippines: Suspension lifted, certain tax compliance actions of revenue officers

4 Aug - UAE: AEOI portal FAQs under FATCA and CRS regimes

4 Aug - United States: Removal of signature requirement for section 754 elections

4 Aug - United States: Credit for renewable fuels reduces excise tax, but deduction limited to excise tax actually paid (Fifth Circuit)

3 Aug - United States: Initial impressions of corporate alternative minimum tax provision in draft Senate reconciliation bill

2 Aug - Bolivia: Guidance concerning tax payment facilities

2 Aug - EU: Proposed directive for debt-equity bias reduction allowance and limiting deductibility of interest for corporate income tax purposes (KPMG comments on DEBRA proposal)

2 Aug - Hong Kong: Intra-group share transfer involving UK LLPs eligible for stamp duty relief (court decision)

1 Aug - Bolivia: Revised rules regarding failure-to-pay penalty

July 2022

29 Jul - Lithuania: Changes to APA rules

28 Jul - Bolivia: Guidance to implement tax administrative and procedural legislative measures

27 Jul - OECD: Progress on harmful tax practices

27 Jul - Singapore: Updated FATCA document for record level errors

27 Jul - UAE: Deadline to file FATCA and CRS reports is now 15 August 2022

27 Jul - United States: Reported agreement on Senate reconciliation bill, legislative text and summary of bill

26 Jul - Bolivia: Revised tax administrative and procedure measures

26 Jul - EU wins WTO case against Turkey's “discriminatory practices” regarding pharmaceutical products

26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw

26 Jul - Poland: Excise goods introduced into free zone exempt from excise markings obligation (court decision)

26 Jul - Poland: No transfer pricing documentation or Local file reporting obligation on contribution to foreign company’s supplementary capital

26 Jul - United States: Taxpayer’s claim for reimbursement of “protest payments” denied, no statutory basis for refund (Eleventh Circuit)

26 Jul - United States: Allowance of deductions and credits on Form 1120-F delinquent returns

25 Jul - Cambodia: Site visits by tax authority to enterprises in Phnom Penh

25 Jul - India: Amendment with respect to nondeductible expenses does not have retroactive effect (high court decision)

25 Jul - India: Guidance that deferred payments for road construction not exempt from GST held invalid (high court decision)

25 Jul - UK: HMRC consultation on collecting data from taxpayers

25 Jul - UK: New transfer pricing documentation rules effective for accounting periods beginning on or after 1 April 2023

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)

June 2022

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

May 2022

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)

April 2022

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

March 2022

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

February 2022

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

January 2022

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

2021 Articles

December 2021

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

November 2021

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

October 2021

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)

1 Oct - Bermuda: CRS compliance certification form for 2020 due 15 December 2021

1 Oct - Poland: Updated proposals for changes to withholding tax collection rules

September 2021

30 Sep - Hong Kong: Added to EU “grey list” for tax purposes

30 Sep - UAE: Updated FAQs under CRS regime

30 Sep - United States: High court upholds B&O tax surcharge on banks (Washington State)

30 Sep - KPMG report: LIBOR transition, transfer pricing considerations of intercompany financial arrangements

29 Sep - KPMG report: Managing transfer pricing and customs risks of cross-border transactions

29 Sep - Cyprus: Extension of filing date for income tax returns for 2019, companies and self-employed

29 Sep - Germany: Interest rate of 6% for tax deficiencies, refunds held unconstitutional

29 Sep - Jordan: Instructions for implementing transfer pricing regime include documentation requirements

28 Sep - United States: House Budget Committee’s report on “Build Back Better Act” (the reconciliation bill)

28 Sep - United States: Updated list of countries, deposit interest paid to nonresident aliens (Chile, Dominican Republic, Singapore)

28 Sep - EU: Update on "public" country-by-country reporting

28 Sep - Channel Islands: Amendments to FATCA and CRS regulations (Guernsey)

27 Sep - Switzerland: Arm’s length price and transfer pricing implications of financial guarantees

27 Sep - Germany: Application of EU Parent-Subsidiary Directive when partnership acts as intermediary (court decision)

27 Sep - Germany: Attribution of profits of permanent establishment without personnel (court decision)

27 Sep - United States: Companies agree to settle violations of Ukrainian and Sudanese sanctions

24 Sep - EU: CJEU actions in tax cases; other tax-related actions of EU institutions 

22 Sep - United States: Resource and information about refunds subject to review by Joint Committee on Taxation (IRS webpage)

22 Sep - United States: Senate approves Assistant Secretary for Tax Policy

22 Sep - British Virgin Islands: FATCA reporting obligations, U.S. TIN information is mandatory

22 Sep - Netherlands: Proposal to address mismatches in non-arm’s length transfer pricing

22 Sep - Saudi Arabia: Merger of tax and customs authorities is completed

21 Sep - Cyprus: Effective date of tour operators’ margin scheme (court decision)

20 Sep - Austria: Approaching deadline of 30 September for claiming investment premium for fixed assets, for VAT refunds; standard audit file update

20 Sep - Belgium: Treaty relief with Luxembourg, for cross-border workers

20 Sep - Bermuda: Compliance actions under CRS requirements

20 Sep - Germany: Updated CRS guidance, self-certification

20 Sep - Hong Kong: Taxation of share grants when subject to forfeiture provisions (court decision)

20 Sep - Poland: “Executed tax strategy” reporting requirements, include transfer pricing information

20 Sep - Singapore: Determining when certain machinery is excluded from property tax (court decision)

20 Sep - United States: IRS acceptance of non-traditional real property (such as fiber optic cable) for REIT income tests

17 Sep - Czech Republic: Vacation rentals via online marketplace held business activity, not property lease

16 Sep - Belgium: Excess profit ruling system and state aid scheme (CJEU judgment)

16 Sep - Netherlands: Updated FATCA and CRS guidance

16 Sep - Peru: Approaching deadline for secondary filing by U.S. multinationals of FY 2020 country-by-country reports

16 Sep - Serbia: Key dates for implementing tax administrative measures

16 Sep - United States: Tax proposals for budget reconciliation legislation approved by Ways and Means

16 Sep - United States: Section 263A costs for self-constructed assets; limitation of exchange gain or loss (IRS practice units)

15 Sep - EU: Energy taxation directive

15 Sep - Nigeria: Rivers State government asks high court to dismiss order staying VAT enforcement

15 Sep - Spain: Deadline to claim VAT refund for 2020 is 30 September 2021

14 Sep - Indonesia: Ratification of tax treaties with UAE and with Singapore

14 Sep - Namibia: Transfer pricing adjustments when transaction not at arm’s length

13 Sep - United States: JCT estimated budgetary effects, technical explanation of revenue-raising Ways and Means proposals

13 Sep - United States: Ways and Means releases additional proposals for markup, including tax increases

13 Sep - Nigeria: Court of Appeal orders Nigerian states to maintain status quo on VAT administration

13 Sep - Singapore: New release of transfer pricing guidelines

13 Sep - Taiwan: Customs requirements when making one-time transfer pricing adjustments

13 Sep - UK: HMRC guidance on disclosing coronavirus job retention scheme (CJRS) claims

10 Sep - Kenya: Effect of late filing of VAT returns on input VAT claims (High Court decision)

10 Sep - Nigeria: Authority of states to collect stamp taxes (duties)

10 Sep - United States: IRS Priority Guidance Plan for 2021-2022

10 Sep - United States: Senate Finance Committee chairman releases discussion draft on reforming taxation of passthrough entities

9 Sep - United States: Company to pay $189,000 to settle violations of Iranian sanctions

9 Sep - United States: Determination, disposable gloves from Malaysia not produced by forced labor

8 Sep - Thailand: Reduced withholding tax for payments made via e-withholding system extended through 2022

8 Sep - Cayman Islands: Updated FATCA and CRS guidance

8 Sep - Nigeria: VAT legislation introduced (Lagos State)

7 Sep - Nigeria: Rivers State government orders implementation of state VAT law

7 Sep - Ukraine: Draft legislation concerning the digital economy

7 Sep - United States: Draft forms and instructions in W-8 series

7 Sep - United States: Ways and Means announces first part of budget reconciliation markup, includes qualified plan proposals

3 Sep - United States: Penalty for failure to deposit taxes under CARES Act (Chief Counsel legal advice memo)

3 Sep - Botswana: Threshold for preparing and filing transfer pricing documentation

2 Sep - Cayman Islands: Updated portal user guide

2 Sep - India: Indirect transfer-related provisions; due dates of electronic filing of forms extended

2 Sep - Malaysia: Study of special voluntary disclosure program for indirect tax

1 Sep - United States: Foreign tax credit (business) general principles (IRS practice unit)

1 Sep - Kazakhstan: “Pilot project” on electronic VAT invoicing exemption

1 Sep - Serbia: Rules relating to electronic invoicing (e-invoicing)

1 Sep - Taiwan: Guidance on application of income tax treaties amended

August 2021

31 Aug - EU: CJEU judgment and referrals, infringement procedures, other developments

31 Aug - EU: Transitional preferential rules of origin under pan-Euro-Mediterranean (PEM) Convention

31 Aug - Germany: Interest rate of 6% for back taxes and tax refunds unconstitutional

31 Aug - Germany: New administrative guidelines for transfer pricing

31 Aug - Hong Kong: Updated AEOI self-certification template for “controlling persons”

31 Aug - Ireland: Updated filing guidelines under CRS regime

31 Aug - Taiwan: CRS data for 2020

30 Aug - Nigeria: VAT, other taxes outside jurisdiction of federal government (Federal High Court)

30 Aug - UK: Draft guidance on uncertain tax treatments

30 Aug - UK: Estoppel by convention used by HMRC (Supreme Court decision)

26 Aug - United States: UK financial institution agrees to pay $2.3 million to settle Sudan sanction violations

25 Aug - United States: Senate Finance Committee chairman, Democratic members: Discussion draft on overhauling U.S. international taxation

25 Aug - United States: Interest rates, tax underpayments and overpayments (no changes for fourth quarter 2021)

25 Aug - Cayman Islands: CRS compliance form deadline

25 Aug - KPMG report: Digitalization driving new operating models for financial services industry; transfer pricing considerations

24 Aug - United States: House passes budget resolution; implications for major tax legislation

24 Aug - United States: Revised applicability date, withholding and reporting regarding publicly traded partnership interests

24 Aug - United States: Transfers of property to partnerships; accuracy-related penalty and reportable transactions (IRS practice units)

23 Aug - United States: Colorado (federal tax conformity); North Carolina (sourcing, asset management services); Texas (sourcing, satellite radio service)

23 Aug - United States: IRS opens application period for 2022 Compliance Assurance Process (CAP) program

23 Aug - India: Payments for use of online advertising, marketing, and IT facilities not taxable as royalties under tax treaties

20 Aug - Germany: Updated CRS guidance

19 Aug - Chile: Guidance regarding tax examinations

17 Aug - Australia: Corporate tax transparency data to be published

17 Aug - India: Activities constituting PE under tax treaty with Norway; treaty benefits on company’s re-domiciliation

17 Aug - India: Tax relief, computation when book profit increase due to APA or secondary adjustments

16 Aug - United States: Treaty provisions do not allow foreign tax credit offset against net investment income tax (U.S. Tax Court)

12 Aug - United States: Senate infrastructure bill would expand cryptocurrency tax reporting

12 Aug - Netherlands: Increased monitoring of import declarations by Dutch Customs

11 Aug - Bahrain: Economic substance information returns due 31 August 2021

11 Aug - Czech Republic: Tax treatment of disposal costs of assets (Supreme Administrative Court decision)

11 Aug - Czech Republic: Transfer pricing issues remain under scrutiny

11 Aug - United States: Senate passes budget resolution; implications for major tax legislation

10 Aug - United States: Senate approves infrastructure bill, including tax provisions

10 Aug - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 16 August

10 Aug - China Customs streamlines penalty provisions

9 Aug - United States: California company to pay $6.6 million penalty for software exports violating U.S. arms regulations

9 Aug - Hong Kong: Guidance addresses tax residence, permanent establishment, cross-border employee issues

9 Aug - Vietnam: Updated FATCA guidance

6 Aug - India: Capital gains on transfers of shares of foreign company; due dates for electronic filing extended

6 Aug - South Africa: Proposal to address tax avoidance on wealth transfers to certain trusts by individuals

5 Aug - South Africa: Proposed penalty regime, individual taxpayers not filing income tax returns

5 Aug - Luxembourg: Transposition of EU directive, cross-border distributions of collective investment undertakings

5 Aug - OECD: Countries bring preferential tax regimes in line with international standards

5 Aug - Panama: FATCA reporting deadline extended to 15 August 2021

4 Aug - United States: Penalty for failure to include reportable transaction information (IRS practice unit)

4 Aug - India: Long-term capital loss on sale of shares by foreign company allowed, not sham transaction

4 Aug - Mauritius: Income tax treaty with Lesotho

3 Aug - OECD: Transfer pricing country profiles; updated for financial transactions and permanent establishments

3 Aug - Australia: Common loss carryback errors identified

3 Aug - Mexico: Extension of time, outsourcing personnel rules

3 Aug - UK: Tax on overseas dividends, reliefs, interest (Supreme Court decision in FII group litigation)

3 Aug - United States: Competent authority arrangements on derivative benefits under income tax treaty with United Kingdom

2 Aug - United States: Senate releases legislative text of bipartisan infrastructure bill

2 Aug - Bulgaria: Income tax treaty with the Netherlands

2 Aug - China: Simplified procedure for unilateral APAs

2 Aug - Japan: Protocol to amend income tax treaty with Switzerland

July 2021

30 Jul - UK: Large businesses required to disclosure uncertain tax treatment in tax returns

30 Jul - Mauritius: Extended deadline for FATCA and CRS reporting

29 Jul - Poland: Transfer pricing measures in proposed tax legislation

28 Jul - United States: IRS scrutiny of hospitals’ net operating losses

28 Jul - United States: Overview of section 987 and branch operations in a foreign currency (IRS practice unit)

28 Jul - United States: Treaty claims and Form W-8BEN-E

28 Jul - Canada: Temporarily suspended limitation periods to resume 1 September 2021 (Quebec)

28 Jul - EU: CJEU judgment and EFTA referral, state aid ruling, other developments

28 Jul - Hungary: Delayed implementation date, tentative VAT returns prepared by tax authority

27 Jul - India: Advertisement and sales promotion, post-import activity and not includible in assessable value of imports (Supreme Court decision)

26 Jul - United States: Indiana (franchise fee litigation); Michigan (advertising materials)

26 Jul - United States: IRS revises system for filing information returns electronically

21 Jul - United States: Electronic-filing requirements for specific tax returns, other documents (proposed regulations)

21 Jul - Costa Rica: Change to taxpayer status for failures to file returns

20 Jul - Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance

20 Jul - Hong Kong: Restricted shares issued under termination agreement not subject to salaries tax (court decision)

19 Jul - Netherlands: Interest deduction denied in acquisition structure (Dutch Supreme Court)

19 Jul - Sri Lanka: Transfer pricing rules, documentation requirements

19 Jul - U.S. and UAE companies agree to settle violations of Iranian sanctions

19 Jul - United States: Arizona (digital data); California (SALT cap work-around); Oregon (corporate activity tax)

16 Jul - United States: Section 482 adjustments for cost-sharing agreements with reverse claw-back provisions (Chief Counsel legal advice memo)

16 Jul - EU: Infringement proceedings and referrals to CJEU, other developments

15 Jul - Bahrain: Country-by-country reporting and notification obligations

15 Jul - Oman: Clarification of suspension of country-by-country reporting

14 Jul - Netherlands: Formal investigation of tax rulings, transfer pricing issues (EU General Court)

13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021

13 Jul - Panama: List of reportable jurisdictions updated; CRS reporting deadline extended

13 Jul - Romania: Guide for new tax reporting procedure

13 Jul - Russia: Transfer pricing audits, focus on pre-audit analysis

13 Jul - Nigeria: Tax assessment upheld, retroactive reduction of “tax holiday” for petroleum companies (tribunal decision)

13 Jul - Seychelles: Tax amnesty available through December 2021

12 Jul - EU: European Commission expected to act swiftly once global agreement is reached; G20 Finance Ministers endorse key components of the two pillars

12 Jul - Netherlands: Interest deduction on group loan, hybrid elements in group structure (Supreme Court judgment)

10 Jul - G20 Finance Ministers conclude meeting with agreement for global minimum tax, other measures

9 Jul - United States: FDII and computing qualified research expenses (IRS practice units)

8 Jul - United States: Five-year suspension of tariffs, large civil aircraft disputes with EU and UK

8 Jul - Oman: Country-by-country reporting is suspended

6 Jul - Japan: Updated guidance (Q&As) under group relief system

6 Jul - Madagascar: Transfer pricing documentation requirements

2 Jul - United States: Foreign tax redeterminations (IRS practice unit)

2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0

2 Jul - United States: Ways and Means, Finance chairs express support for global minimum tax

2 Jul - Canada: Guidance on obtaining Competent Authority assistance, MAP requests and transfer pricing adjustments

2 Jul - Finland: Updated FATCA guidance concerning U.S. TINs

1 Jul - EU: European Commission consultations, European Parliament hearings, ECOFIN report (July 2021)

1 Jul - OECD: Statement of Inclusive Framework on two-pillar solution addressing tax challenges of digital economy

1 Jul - United States: California’s requirements for disclosure of identities of donors violates First Amendment (U.S. Supreme Court)

June 2021

30 Jun - Germany: Legislation transposing ATAD measures (exit taxation, CFC rules, hybrid mismatches)

30 Jun - Germany: Provisions amending arm’s length principle, transfer pricing

30 Jun - United States: Allocation methods of personal use of aircraft (IRS practice unit)

29 Jun - United States: IRS memorandum on TE/GE exam activities

29 Jun - Liechtenstein: CRS and FATCA controls for managed legal entities, banks and insurance companies

29 Jun - Singapore: GST implications of common transfer pricing adjustments

29 Jun - South Africa: Transfer pricing adjustments and implications for VAT purposes

28 Jun - Brazil: Second phase of tax reform proposals are outlined

28 Jun - EU: Changes to VAT rules affecting cross-border e-commerce effective 1 July 2021

28 Jun - Germany: Updated FATCA, CRS guidance

28 Jun - Jordan: Transfer pricing regulations are introduced

28 Jun - Ukraine: Income tax and VAT implications of intra-group services

25 Jun - Australia: ATO revises guidance on tax treatment of software royalties

25 Jun - Austria: The right to use software can qualify as VAT-exempt asset management (CJEU judgment)

25 Jun - Azerbaijan: Update on country-by-country reporting

25 Jun - Liechtenstein: Updated FATCA guidance

24 Jun - United States: IRS releases tax collection data for fiscal year 2020

23 Jun - Ireland: Updated guidance on treatment of profit-sharing plans for FATCA, CRS purposes

22 Jun - Germany: Updated CRS guidance

22 Jun - Isle of Man: Economic substance rules extended to partnerships

22 Jun - OECD: Reporting rules for platform operators regarding sellers in “sharing and gig economy”

21 Jun - United States: Illinois (manufacturing exemption); Iowa (bonus depreciation); New York State (non-filer liability); Texas (marketplace facilitator)

21 Jun - Finland: Updated CRS technical guidance

21 Jun - Qatar: Deadline for filing Master files and Local files extended to 30 September 2021

18 Jun - Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures

18 Jun - Malaysia: Common transfer pricing issues arising from intra-group services

18 Jun - UK: Tax tribunal decision confirming tax deductibility of deferred revenue expenditure

18 Jun - Channel Islands: Economic substance and partnerships (Guernsey)

18 Jun - United States: IRS practice unit: Concepts of GILTI

17 Jun - United States: Implications for protective refund claims for ACA-related taxes and fees (U.S. Supreme Court)

17 Jun - United States, United Kingdom to suspend trade countermeasures for five years, large civil aircraft dispute

16 Jun - United States: House passes bill requiring country-by-country reporting of pre-tax profits, taxes paid

16 Jun - United States: Scheduled outage of FATCA systems

15 Jun - EU: Update on status of “public” country-by-country reporting

15 Jun - Finland: Updated FATCA technical guidance

15 Jun - Sweden: Interest-deduction limitation rules contrary to EU law; EC formal notice

15 Jun - United States: Free trade agreement between Australia and UK

14 Jun - United States: Colorado (marketplace facilitator); Nevada (mining excise tax); Nevada (business tax refunds); Vermont (taxable meal facilitator); Washington State (payroll tax, B&O surcharge)

14 Jun - United States: Permanent establishment-related considerations, employees working remotely

14 Jun - United States: Treasury releases the American Families Plan tax compliance agenda

11 Jun - China: Instructions for submitting CRS annual reports

11 Jun - Kenya: Country-by-country reporting proposal in budget 2021-2022

11 Jun - Spain: Final rules for digital services tax; first declaration is due July 2021

11 Jun - United States: Nonacquiescence to Eleventh Circuit decision, professional employer organization’s claims for FICA credits (AOD 2021-3)

11 Jun - United States: Partner’s outside basis (IRS practice unit)

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

10 Jun - United States: Mandatory 60-day postponement of tax deadlines, federally declared disasters

10 Jun – United States: Senate Finance Committee approves Treasury Department officials, including Assistant Secretary for Tax Policy

10 Jun - Nigeria: Guidance for filing naira-denominated tax returns electronically

9 Jun - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 31 July 2021

9 Jun - Cayman Islands: Updated FATCA and CRS guidance

9 Jun - Czech Republic: Status of digital services tax legislation

8 Jun - EU: G7 communique on coordinated reforms of international tax system, European perspective

8 Jun - Netherlands: Termination of income tax treaty with Russia

8 Jun - Switzerland: Implications of EU “public” country-by-country reporting for Swiss groups

8 Jun - Thailand: Monthly tax return filing, payment deadlines extended

7 Jun - Cyprus: DAC 6 cross-border arrangements, reporting deadline extended to 30 September 2021

7 Jun - Japan: Requirements for electronic recordkeeping of tax-related books and records

Jun 7 - KPMG report: Analysis and observations about tax measures in G7 communique

7 Jun - Saudi Arabia: Guidelines and standards for e-invoices

7 Jun - United States: New Jersey (Public Law 86-272); New Jersey (NOL carryforward); Maryland (digital advertising services); Tennessee (sales tax holiday); multistate (corporate tax rate reductions)

4 Jun - United States-Switzerland: Competent authorities add individual savings plans as eligible for dividend benefits under tax treaty

4 Jun - Cyprus: Income tax treaty with the Netherlands

3 Jun - India: GST Council recommends reducing compliance burden

3 Jun - Malaysia: Penalty relief for late payment of GST; service tax exemption for joint development area

3 Jun - Qatar: Reminder of deadlines for tax returns for 2020

2 Jun - United States: Taxpayer not a “bank” and thus not allowed to deduct certain losses (Fifth Circuit)

2 Jun - United States: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed) (Ninth Circuit)

2 Jun - EU: Political agreement on “public” country-by-country reporting requirements

2 Jun - France: Updated FATCA technical guidance

2 Jun - Taiwan: CRS reporting deadline extended to 2 August 2021

1 Jun - Argentina: Proposal to revise corporate income tax rates, pending in Congress

1 Jun - Australia: Evidence relevant for determining arrangements are at arm’s length (High Court decision)

1 Jun - EU: State aid determinations, referrals to CJEU, other developments

1 Jun - Germany: Cross-border company “split-up” (court decision of first impression)

1 Jun - Poland: Tax proceedings initiated to suspend limitations period; identifying rental and lease revenue

1 Jun - UAE: Clarifications about tax penalty regime

May 2021

31 May - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2022 budget

28 May - United States: Initial impressions of tax proposals in Biden Administration’s budget for FY 2022

28 May - United States: Green Book—Treasury’s explanation of tax proposals in FY 2022 budget

28 May - United States: Biden Administration’s budget proposals for FY 2022

28 May - Bahrain: Economic substance returns, deadline extended to 31 July 2021

28 May - Channel Islands: Economic substance rules for partnerships (Jersey)

28 May - Ireland: Updated filing guidelines for FATCA

28 May - KPMG report: Comments on proposed changes to Commentaries in OECD Model Tax Convention, Article 9 and related articles

28 May - Brazil: Status of possible transfer pricing rules

28 May - Hong Kong: What are possible considerations for BEPS 2.0?

28 May - Taiwan: Amended CRS measures

27 May - India: FATCA and CRS reporting deadlines extended to 30 June 2021

26 May - South Africa: Documentation for interest-free or low-interest loans involving trusts

26 May - Ukraine: Withholding tax rates under tax treaty and “principal purpose test” (court decision)

25 May - United States: FATCA responsible officer certifications due 1 July 2021

25 May - Barbados: AEOI web portal for FATCA and CRS filings, open until 1 June 2021

25 May - Channel Islands: No deadline changes for FATCA and CRS reporting (Guernsey)

25 May - Germany: Updated FATCA guidance

25 May - Malta: Country-by-country reporting, penalties for non-compliance

25 May - Saudi Arabia: Tax and customs authorities merge into single authority

25 May - UK: Supreme Court dismisses HMRC’s appeal; “staleness” and discovery assessments

24 May - EU: Consultation on rules to neutralize misuse of shell entities; recommendation on domestic tax treatment of losses

24 May - Italy: Updated list of reportable, participating jurisdictions for AEOI under CRS regime

24 May - Nigeria: Suspended country-by-country reporting requirements for MNE branches and subsidiaries

24 May - Thailand: Proposed temporary reduction of customs duty surcharge for inadvertent underpayments

24 May - United States: Missouri (remote sellers, marketplace facilitators); Indiana (pharmacy benefits management); Nevada (modified business tax rate)

24 May - United States: Allocation and apportionment of deductions, individual taxpayers (IRS practice unit)

20 May - United States: Tax reform proposals—BEAT down, SHIELD up

20 May - United States: Treasury’s report on proposed tax compliance measures; addressing the “tax gap”

20 May - United States: Treasury officials participate in OECD meetings, proposal for global corporate minimum tax rate

20 May - Channel Islands: FATCA and CRS updates (Jersey)

20 May - India: Amendments to GST refund rules and procedures

20 May - India: “Faceless” audits and future rules expected for transfer pricing audits

20 May - Kenya: Country-by-country proposals in Finance Bill, 2021

20 May - Luxembourg: Updated CRS FAQs

20 May - Tanzania: Rendering of intra-group services and transfer pricing audits

20 May - Australia: Intangibles arrangements; a deeper look at ATO’s draft practical compliance guideline

19 May - Australia: Draft compliance guideline, transfer pricing and international arrangements involving intangible assets

19 May - EU: Analysis of proposed business tax framework

19 May - Qatar: FAQs address transfer pricing documentation

18 May - Bahrain: FAQs on country-by-country reporting

18 May - Barbados: AEOI portal for FATCA and CRS reports, open until 31 July 2021

18 May - Belgium: Tax administration focuses on directors, executives with management responsibilities at foreign company

18 May - EU: CJEU, European Commission, European Parliament updates; state aid rulings (May 2021)

18 May - Poland: Transfer pricing documentation, preliminary agreements and tax haven-related transactions

18 May - Serbia: Measures revising tax treatment of independent contractors

18 May - Singapore: CRS guidance concerning qualifying personal investment companies

17 May - India: Effects of APA on taxable income (royalty) received by foreign taxpayer that is not a party to the APA

17 May - Mexico: List of registered foreign providers of digital services

17 May - United States, EU agree to address steel and aluminum trade issues, customs duties

17 May - United States: CBP headquarters ruling; cotton garments produced in part by forced labor in China

14 May - United States: Updated FAQs provide default codes for missing U.S. TINs

13 May - United States: Eighth Circuit reverses district court, finds regulations are valid

13 May - Finland: Withholding tax refunds claimed by Luxembourg SICAV; potential refund opportunities (CJEU judgment)

13 May - Bulgaria: Transfer pricing documentation; Local file for 2020 required by 30 June 2021

13 May - Canada: Changes to filing procedure for corporate information returns (Ontario)

13 May - Serbia: New electronic invoicing law, VAT implications

13 May - Panama: Default TINs for FATCA reporting

12 May - Czech Republic: Tax treatment of interest on acquisition loan in intragroup restructuring (court decision)

12 May - Luxembourg: Tax rulings provided no selective advantage (EU General Court)

12 May - Luxembourg: Tax rulings granted to companies resulted in tax advantage (EU General Court)

12 May - Singapore: Transfer pricing guide for multinational entity headquarters

12 May - Taiwan: Rules allowing one-time transfer pricing adjustment

12 May - United States: Proposal to require country-by-country reporting of pre-tax profits, taxes paid

11 May - United States: CFCs changing methods of accounting to alternative depreciation system

11 May - KPMG report: Overview of R&D tax incentives, by country (2021)

11 May - EU: New export controls for “dual-use” goods and technologies

11 May - EU: Update on initiatives for public and non-public country-by-country reporting

11 May - KPMG report: Country-by-country reporting; notification requirements per country (updated)

11 May - Nigeria: Tax collection agents reminded to remit taxes collected by deadline

11 May - Saint Kitts and Nevis: Possible extension of CRS reporting deadline

11 May - Serbia: Tax administrative measures effective in 2022

10 May - UAE: Tax-related penalty regime revised

7 May - Bahrain: New electronic filing requirement for economic substance returns

7 May - China: CRS reporting deadline extended to 16 June 2021

6 May - Bermuda: CRS reporting deadline extended to 30 June 2021

6 May - Canada: APA statistics for 2020

6 May - EU: Resolution of European Parliament on taxing digital economy

6 May - Thailand: Extended deadline for corporate income tax return filing, payment

5 May - Liechtenstein: FATCA, CRS reporting deadline extended to 31 July 2021

5 May - Philippines: Updated guidelines for tax treaty relief

5 May - Spain: Transposition of EU directive (DAC 6) completed

5 May - Taiwan: CRS reporting deadline 30 June 2021; new information

4 May - India: Tax treatment of items under income tax treaties with Singapore and the Netherlands

4 May - Kenya: Marketing support services for non-resident entities, zero-rated for VAT purposes (tribunal decision)

4 May - United States: Company to pay $13 million to settle alleged ITAR export violations

4 May - United States: FATCA IDES testing, scheduled for June 2021

3 May - United States: Arkansas (sales tax exemption); Arkansas (NOL add-back); Florida (federal tax conformity); New York City (sale of partnership interest); Washington State (excise tax, capital gain)

3 May - United States: USTR hearings this week, investigations of digital services taxes

3 May - United States: Valuation of performer’s image and likeness, music publishing trust and catalog (U.S. Tax Court)

April 2021

30 Apr - United States: IRS automatically extends QI / WP / WT certification and waiver application due dates

30 Apr - United States: Treatment of expenses related to aircraft owned and used by sole proprietor (IRS Chief Counsel memo)

30 Apr - United States: Schedules K-2 and K-3 for 2021; intended for enhanced reporting of international tax matters by pass-through entities

30 Apr - Singapore: R&D expenses under cost-sharing agreement (appellate court decision)

30 Apr - EU: Actions by and referrals to CJEU, European Parliament and EU Council

29 Apr - Saudi Arabia: Force of attraction rules in relation to permanent establishments

29 Apr - Vietnam: Default TINs for FATCA reporting

29 Apr - United States: Updated list of jurisdictions not issuing foreign TINs

28 Apr - United States: President Biden announces American Families Plan, individual tax proposals

28 Apr - United States: Treasury proposals for tax administration reforms

27 Apr - United States: House Ways and Means chair introduces economic plan, includes tax provisions

27 Apr - United States: Legal expenses for FDA approvals capitalized, but those for defending patent infringement suits are deductible (U.S. Tax Court)

27 Apr - Kenya: Application of commercial building allowance for years before 2010 (High Court decision)

27 Apr - Switzerland: New income tax treaty with Brazil

27 Apr - British Virgin Islands: FATCA, CRS deadlines extended to 30 June 2021

27 Apr - Kenya: No withholding tax on payments to South African entity under income tax treaty

26 Apr - Australia: Additional default TIN under FATCA regime

26 Apr - Poland: “Ready-to-eat meals” subject to reduced VAT rate (CJEU judgment)

26 Apr - United States: Arizona (federal tax conformity); Illinois (unitary group); Texas (R&D tax credit); Vermont (federal tax conformity)

23 Apr - Belgium: New XML scheme for filing reports related to mandatory disclosure rules (DAC 6)

23 Apr - Malta: Tax returns for 2020, filed by fiscal units

23 Apr - UK: Commercial transaction structured in tax-efficient way not “main purpose” of tax avoidance (tax tribunal decision)

23 Apr - Costa Rica: Income tax treaty with UAE

22 Apr - Cayman Islands: Updated FATCA and CRS guidance

22 Apr - Gibraltar: Process for determining whether legal entities are residents of Spain

22 Apr - Luxembourg: “Zero-value message” filings under FATCA and CRS regimes

22 Apr - United States: Marijuana dispensary’s claimed expenses properly denied (Ninth Circuit)

22 Apr - EU: Review of deemed supply rules for online marketplaces, effective 1 July 2021

21 Apr - EU: Summary of CJEU referrals and judgments; EC actions, country updates (April 2021)

21 Apr - Kenya: Tax authority temporarily restrained from collecting minimum tax

21 Apr - Malta: FATCA, CRS reporting deadlines extended to 30 June 2021

20 Apr - Bahrain: FATCA and CRS reports for 2020 due 31 May 2021

20 Apr - Canada: Tax measures in 2021 federal budget

20 Apr - Malta: Update on expectations for transfer pricing rules

20 Apr - Poland: VAT penalty of 20% held incompatible with EU law (CJEU judgment)

19 Apr - Finland: Updated FATCA and CRS technical guidance

19 Apr - Germany: Insurance premium tax for seagoing vessels (CJEU judgment)

19 Apr - United States: Company agrees to pay $435,000 for imports of engineering services from Iran

19 Apr - United States: Florida (tobacco tax); Maryland (reseller basis for refund); Virginia (reporting unitary combined income)

19 Apr - United States: IRS allows temporary relief from handwritten signature requirement for more tax forms

16 Apr - Singapore: CRS returns for 2020 due by 31 May 2021

16 Apr - Singapore: Guidelines for tax treatment of transactions involving digital tokens

15 Apr - Japan: New FAQ added under CRS regime

15 Apr - Luxembourg: VAT exemption, legal services for adults lacking legal capacity (CJEU judgment)

15 Apr - Nigeria: Transfer pricing awareness survey (KPMG report)

15 Apr - Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures

15 Apr - United States: JCT overview of federal tax system (2021)

15 Apr - United States: Taxation of digital advertising services; sales and use tax on digital products and services (Maryland)

14 Apr - Argentina: New digital services tax procedures for Buenos Aires

14 Apr - Brazil: Review of digital services tax proposals

14 Apr - United States: Recommendations for IRS 2021-2022 Priority Guidance Plan

14 Apr - United States: Updated charts reflecting provisions in President Biden’s business tax proposals

13 Apr - United States: Penalty relief, reduced federal employment tax deposits in anticipation of tax credits

13 Apr - Pakistan: Implications of MLI on income tax treaties

13 Apr - Italy: Withholding tax exemption, interest payed to UK banks during Brexit transition period; possible refund opportunities

13 Apr - Netherlands: Acquisition of real estate legal entity subject to real estate transfer tax

12 Apr - Chile: Tax implications of asset transfers in corporate dissolutions

12 Apr - United States: Maryland (digital advertising, digital products); New York City (services sourcing); Ohio (IP sourcing); West Virginia (apportionment)

12 Apr - United States: Split-dollar arrangement distributions; benefits under compensatory arrangement taxable as ordinary income (U.S. Tax Court)

9 Apr - United States: IRS nonacquiescence, defined benefit pension plan not an asset for insolvency exclusion under section 108 (AOD 2021-1)

9 Apr - United States: IRS reminder, FBAR filing deadline remains 15 April

9 Apr - Belarus: Review of transfer pricing measures effective in 2021

9 Apr - Cayman Islands: Updated FATCA and CRS guidance

9 Apr - UK: Proposals for new transfer pricing documentation, new annual related-party transaction return

9 Apr - Zambia: Amendments to country-by-country reporting rules

8 Apr - Costa Rica: Advance pricing agreements, implementing guidance

8 Apr - Italy: Relief measures suspend tax collection, extend digital services tax deadlines

8 Apr - Poland: Rate of property tax, real estate not used in business activity (tribunal decision)

7 Apr - Malta: Updated FATCA, CRS guidance regarding AEOI

7 Apr - OECD: Report on status of international tax agenda, developments

7 Apr - Singapore: Updated FATCA guidance and FAQs

7 Apr - United States: Treasury releases report “Made in America Tax Plan”

6 Apr - United States: Foreign tax credit carryback and carryover (IRS practice unit)

6 Apr - Oman: Guidance concerning administrative tax disputes and VAT zero-rating for medicines

5 Apr - EU: Summary of CJEU judgments, referrals (April 2021)

5 Apr - Finland: Updated FATCA and CRS technical guidance

5 Apr - Liechtenstein: Updated AEOI guidance

5 Apr - United States: IRS TE/GE division announces new compliance initiatives

5 Apr - United States: Presidential proclamation imposing tariffs on steel “derivatives” held invalid (U.S. trade court)

5 Apr - United States: Senate Finance Committee chairman, Democratic members: Framework on overhauling U.S. international taxation

2 Apr - United States: Liquidating distributions of partner’s interest; reasonable cause and good faith (IRS practice units)

2 Apr - Nigeria: Automated tax system deployed

2 Apr - Russia: Tax audits of individuals with foreign-held assets, accounts

2 Apr - Netherlands: Tax developments concerning financial institutions (April 2021)

1 Apr - Netherlands: Proposed changes to legal forms, possible tax implications

1 Apr - Australia: Synthesised text of income tax treaty with Indonesia

1 Apr - Channel Islands: Updated FATCA guidance, invalid or missing U.S. TINs (Jersey)

1 Apr - United States: Reasonable cause, penalty for failure to remit sufficient advance sales tax payment (Massachusetts)

March 2021

31 Mar - OECD: First exchanges of “no or only nominal tax jurisdictions”

31 Mar - Mauritius: Country-by-country reporting deadline, extension to 20 April 2021

31 Mar - United States: IRS to recalculate taxes on 2020 unemployment benefits, and automatically to issue refunds

30 Mar - United States: APMA program, APA statistics for 2020

30 Mar - United States: USTR announces hearings, requests comments about investigations of digital services taxes (Austria, India, Italy, Spain, UK, Turkey)

30 Mar - Hungary: VAT base reduced by bad debts; five-year limitations period (CJEU judgment)

30 Mar - Italy: VAT online registration portal, reporting cross-border sales and transactions

29 Mar - Australia: R&D tax incentive (Full Federal Court)

29 Mar - EU: European Parliament ECON committee vote on digital economy resolution; reporting requirements for digital businesses (DAC7)

29 Mar - India: Tax treaty benefits not available to Dutch fiscally transparent entity

29 Mar - Kuwait: “No objection letters” regarding tax compliance of foreign lenders

29 Mar - Saudi Arabia: Consultation on e-invoicing proposal

29 Mar - UK: Proposed changes to hybrid mismatch rules

29 Mar - UK: Second consultation regarding uncertain tax treatments by large businesses

29 Mar - United States: Additional tax deadlines extended to 17 May

29 Mar - United States: Clothing designs and patterns not eligible research expenses (U.S. Tax Court)

29 Mar - United States: Receipt of dividends or interest from a related CFC (IRS practice unit)

29 Mar - United States: Maine (federal tax conformity); New Mexico (disposal services); Wyoming (sales tax, car services); Multiple states (COVID relief funds)

26 Mar – United States: Next steps in digital services tax investigations

26 Mar - United States: Italian company to pay $950,000 to settle violations of Iranian sanctions

26 Mar - France: Treatment of pharmaceutical company’s rebates for VAT purposes; refund opportunities

26 Mar - Germany: VAT treatment of license granted by underwriting agent to insurer and insurance mediation services (CJEU judgment)

26 Mar - Portugal: Tax on capital gains realized by non-resident on transfer of immovable property (CJEU judgment)

26 Mar - Serbia: Update on income tax treaties

26 Mar - Switzerland: Guidance on implementing FATCA agreement with United States

26 Mar - UK: “Tax Day” overview of consultations and reviews primarily focused on tax system modernisation

26 Mar - UK: “Tax Day” re-design of tax administration

26 Mar - UK: Updated country-by-country reporting schema

25 Mar - UK: Consultation on transfer pricing documentation requirements

24 Mar - Belgium: Overview of tax and transfer pricing audits of multinational entities

24 Mar - Russia: Updated CRS regulations

24 Mar - Spain: VAT treatment of intra-group services; possible implications of CJEU judgment

24 Mar - United States: One penalty (not multiple) applies for untimely filing of FBAR reporting multiple bank accounts (Ninth Circuit)

23 Mar - United States: Overview of section 965 “transition tax" (IRS practice unit)

22 Mar - United States: Arkansas (rental excise tax); New York (budget proposals); Oregon (nexus and telecommuting workers); Virginia (federal tax conformity)

22 Mar - Serbia: Arm’s length interest rates for 2021

22 Mar - Sweden: Interest deduction limitation rules, taxpayer’s claim allowed (Supreme Administrative Court)

22 Mar - Canada: Mandatory disclosure of information about certain transactions (Quebec)

22 Mar - China: Proposal for simplified process for unilateral APAs

22 Mar - EU: Summary of CJEU judgments, EC actions (March 2021)

22 Mar - Singapore: Tax treatment of termination payments made under separation agreement (High Court)

19 Mar - Nigeria: Preparation and filing of first CRS return for 2020

19 Mar - Poland: EU VAT Directive precludes Polish measures on period for deducting input tax (CJEU judgment)

18 Mar - Mongolia: First transfer pricing tax assessment

18 Mar - United States: IRS memo for TE/GE division; interim guidance on 9100 relief for exemption applications

17 Mar - United States: IRS to extend tax filing deadline to May 17

17 Mar - United States: Updated FAQs under FATCA regime; penalty relief for withholding agents

17 Mar - Canada: CRA report on MAP program and statistics for 2019

16 Mar - Hungary: Tax on advertisement upheld (CJEU judgment)

16 Mar - Luxembourg: Guidance on mutual agreement procedures

16 Mar - Poland: Tax on retail sector upheld (CJEU judgment)

16 Mar - Liechtenstein: Updated guidance on AEOI data transmissions

16 Mar - United States: Sale of a partnership interest (IRS practice unit)

15 Mar - United States: Alabama (composite returns); Massachusetts (pandemic telecommuting); Virginia (combined reporting); Mississippi, Oklahoma, West Virginia (tax reform)

15 Mar - United States: Company to pay $216,000 to settle violations of Iranian sanctions

15 Mar - United States: IRS addresses electronic filing of Form 990-T

15 Mar - United States: Tax Court holds microcaptive insurance company arrangement fails; accuracy-related penalties warranted

15 Mar - Cayman Islands: Updated FATCA and CRS guidance

15 Mar - Mexico: Registration reminder for foreign providers of digital services

15 Mar - Netherlands: Third amendment, bill on dividend withholding tax in cross-border reorganizations

12 Mar - Sweden: VAT on services provided by head office to fixed establishment involving VAT group (CJEU judgment)

11 Mar - Netherlands: Update about tax treaty negotiations with Russia

11 Mar - South Africa: Third-party data annual submissions for AEOI

11 Mar - South Africa: Transfer pricing implications of catch-up payments and retroactive adjustments

10 Mar - Italy: Extended deadlines for digital services tax

10 Mar - OECD: Toolkit on tax treaty negotiations, for use by developing countries

10 Mar - United States: Guidance on digital products and streaming tax; SaaS determined to be taxable (Maryland)

9 Mar - Australia: FATCA reporting deadline extended; U.S. TIN information mandatory for 2020 reporting year

9 Mar - Austria: Technical guidance on changes to CRS XML schema

8 Mar - Netherlands: Mismatches in non-arm’s length transfer pricing, consultation on proposal

8 Mar - United States: Alabama (city use tax); Connecticut (taxation of remote work); Multistate (federal tax conformity)

8 Mar - EU: Negotiations with United States concluded to adjust agricultural quotas

5 Mar - EU: Negotiating positions of EU Council and European Parliament, proposal for “public” country-by-country reporting

5 Mar - Channel Islands: FATCA guidance related to missing U.S. TINs (Jersey)

5 Mar - Channel Islands: FATCA and CRS reporting guidance, compliance statement assurance (Guernsey)

5 Mar - United States: European Union and United States to suspend tariffs, large civil aircraft disputes

4 Mar - Spain: Tax regime benefitting professional football clubs; rules on determining state aid (CJEU judgment)

4 Mar - Taiwan: Updated user guide, CRS portal

3 Mar - Germany: Transfer pricing documentation guidelines, cross-border transactions between related parties

3 Mar - OECD: Technical changes in CRS XML schema 2.0

3 Mar - United States: IRS memo for TE/GE examiners; interim guidance on “section 506 notifications”

2 Mar - United States: Interest rates, tax underpayments and overpayments (second quarter 2021)

2 Mar - United States: Updated FAQs for QI / WP / WT

1 Mar - United States: First formal communication of “initial determination” asserting civil fraud penalty lacked prior supervisory approval (U.S. Tax Court)

1 Mar - United States: Maine (sales tax, cell phones); Massachusetts (digital advertising): New York State (resale, sales tax); Tennessee (sales tax, professional dues); Wisconsin (dividends-received deduction)

1 Mar - United States: Test case concerning “first sale” valuation and non-market economies (U.S. trade court)

1 Mar - EU: Update on “public” country-by-country reporting proposal, following discussion by ministers

1 Mar - Germany: VAT on cross-border provisions of company vehicles to employees (CJEU judgment)

1 Mar - Oman: Tax treaty with Sri Lanka, entry into force

1 Mar - Qatar: Transfer pricing documentation guidelines

February 2021

26 Feb - France: Updated FATCA technical guidance

26 Feb - OECD: United States drops “safe harbor” request on proposed digital tax rules

25 Feb - Liechtenstein: Updated FATCA technical guidance for missing TIN

25 Feb - Panama: Guidance for issuing electronic tax receipts and invoices

25 Feb - United States: CRS report on U.S. measures to address Huawei-related issues

25 Feb - United States: IRS focus on improper refund claims relating to domestic production activities deduction

25 Feb - United States: Section 263A computation for producers

24 Feb - United States: Credit card “reward dollars” held taxable income (U.S. Tax Court)

23 Feb - EU: Summary of tax developments including referrals to CJEU, state aid, local law and regulations (February 2021)

23 Feb - Switzerland: Court decision restricts application of U.S. tax treaty on basis of citizenship

23 Feb - Germany: Updated CRS guidance

23 Feb - Malaysia: Update, taxation of digital services by foreign service providers

22 Feb - Argentina: Tax benefits under regime to promote digital “knowledge” economy

22 Feb - Colombia: Tax calendar for 2021

22 Feb - EU: Status of proposal for public country-by-country reporting

22 Feb - EU: Updated “blacklist” of non-cooperative jurisdictions (Dominica added); revisions to “grey list”

22 Feb - Japan: Extended due date for individual income tax returns, payments

22 Feb - Switzerland: Updated CRS technical guidance

22 Feb - United States: Illinois (proposed corporate tax measures); New York State (sales tax, assets acquired under purchase agreement); Pennsylvania (retailer voluntary compliance); Utah (GILTI and FDII)

19 Feb - France: Updated CRS technical guidance

18 Feb - United States: Company to pay $507,000 to settle violations of multiple sanctions programs

17 Feb - Argentina: Exchanges of country-by-country reports, agreement with United States

17 Feb - Korea: Transfer pricing-related amendments in tax legislation

17 Feb - Liechtenstein: Updated CRS technical guidance

17 Feb - South Africa: Transfer pricing adjustment upheld; no transfer pricing documentation

16 Feb - North Macedonia: Disclosure requirements, ultimate beneficial owners

16 Feb - Australia: Objections on hold as tax authority appeals JobKeeper case

16 Feb - Dominican Republic: Tax amnesty, 90-day extension for applications by taxpayers

16 Feb - France: Taxpayer-favorable court decisions, administrative guidance on intragroup financial transactions

15 Feb - Costa Rica: Relief from certain information reporting on form D151

15 Feb - Germany: Updated CRS guidance for financial institutions

15 Feb - UK: Definition of “structure” for capital allowances purposes (Court of Appeal decision)

15 Feb - United States: Alabama (corporate tax); Louisiana (franchise tax); Maryland (taxation of digital products); New York (rental equipment, sales tax)

15 Feb - United States: Interest capitalization for self-constructed assets (IRS practice unit)

12 Feb - Mauritius: Protocol amending tax treaty with Eswatini (Swaziland)

12 Feb - Australia: ATO focus on cross-border financing arrangements

11 Feb - Canada: APA cost-recovery charges cancelled

11 Feb - Germany: Proposed revisions to transfer pricing rules

11 Feb - Malta: Updated FATCA, CRS guidelines on AEOI

11 Feb - United States: Research tax credit disallowed (U.S. Tax Court)

10 Feb - United States: Last in-first out (LIFO) records (IRS practice unit)

10 Feb - EU: Summary of EU tax developments concerns state aid, EU institutions, and local law and regulations (February 2021)

10 Feb - Rwanda: Transfer pricing rules

9 Feb - Czech Republic: Evidence establishing a foreign entity’s permanent establishment (court decision)

9 Feb - Serbia: Income tax treaties, as of 1 January 2021

9 Feb - Nigeria: Investment tax credit, production-sharing contracts and oil prospecting license (appeals court decision)

9 Feb - United States: Fees paid by U.S. company to German parent company under sourcing-assistance agreement not dutiable

8 Feb - United States: California (medical ultrasound services); Illinois (marketplace facilitators); Oregon (Portland “homeless” tax); Multistate (CEO compensation, excise tax proposals)

8 Feb - United States: IRS TE/GE division releases summary of “FY 2020 accomplishments”

5 Feb - United States: Trade court finds tariffs on steel imports did not violate Section 232

5 Feb - Cambodia: System for e-filing income tax returns; tax relief

5 Feb - Singapore: CRS registration deadline is 31 March 2021

4 Feb - Australia: ATO guidance, presence of employees not creating permanent establishment

4 Feb - Croatia: Arm’s length interest rate on loans between related parties for 2021

4 Feb - Hong Kong: Updated FAQs concerning AEOI and CRS regime

4 Feb - Norway: New VAT return, electronic filing expected in 2022


Tax Dispute Resolution Quarterly

The Summer 2021 edition of Tax Dispute Resolution Quarterly features articles on:

  • Remarkably unremarkable APA results
  • U.S. tax reform: BEAT down, SHIELD up
  • MAP, more MAP, and ICAP
  • Misalignment of CbC reporting and value
  • Transfer pricing takeaways from Coca-Cola case
  • Survey of global secondary adjustment rules.

Read the Summer 2021 Tax Dispute Resolution Quarterly

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