Subscribe to TaxNewsFlash. 
Questions? Send an email.

Tax Dispute Resolution Quarterly

Tax Dispute Resolution Quarterly

Read the Spring 2023 edition

Mark R. Martin

Mark R. Martin

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

September 2023

29 Sep - Slovakia: Guidance on proving identity of beneficial owner of income

29 Sep - Spain: EC decision of unlawful State aid annulled to protect legitimate expectations (CJEU General Court judgment)

29 Sep - United States: Additional guidance on beneficial ownership information reporting requirements

29 Sep - United States: IRS Priority Guidance Plan for 2023-2024

29 Sep - United States: IRS provides tax relief for taxpayers in Louisiana affected by seawater intrusion

29 Sep - United States: IRS TE/GE division provides two new technical guides

29 Sep - United States: Wash sale relief for certain redemptions of shares in money market funds

28 Sep - Japan: 2023 tax reform amendments to electronic preservation system for account books

28 Sep - OECD: MLI signed (Eswatini); instrument of ratification of MLI deposited (Côte d'Ivoire)

28 Sep - United States: Guidance on employer leave-based donation programs aiding Hawaii wildfire victims

28 Sep - United States: IRS contingency plan during possible government shutdown

28 Sep - United States: New CAMT guidance in Notice 2023-64 expands scope, increases compliance burdens

27 Sep - United States: 30-day time limit for requesting collection due process hearing subject to equitable tolling (U.S. Tax Court)

27 Sep - United States: Application period for environmental justice solar and wind capacity limitation program opens 19 October

27 Sep - United States: Extended filing deadline for certain beneficial ownership information reports

27 Sep - United States: Farmers, ranchers affected by drought allowed more time to replace livestock

27 Sep - United States: Guidance on new energy efficient home credit under section 45L

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

27 Sep - India: Buyback of shares subject to dividend distribution tax (tribunal decision)

26 Sep - Poland: Amendments to decrees on transfer pricing reporting now effective

26 Sep - Poland: Look-through approach for dividend exemption; tax treatment of losses incurred by Romanian branch; no VAT on stolen goods (court decisions)

26 Sep - Poland: Tax consequences of issuing fake invoice by employee without knowledge of employer (CJEU Advocate General opinion)

26 Sep - Australia: Guidance on correcting GST and fuel tax errors for prior tax periods

26 Sep - Austria: Summary of recent direct and indirect tax developments

26 Sep - South Africa: Cancellations of customs-related registrations and licences

26 Sep - United States: DHS updates Uyghur Forced Labor Prevention Act (UFLPA) entity list

25 Sep - Korea: Fee paid to foreign parent company was royalty subject to withholding tax (Tax Tribunal decision)

25 Sep - Korea: Products provided free of charge under purchase agreement were not “free of charge imports” (Supreme Court decision)

25 Sep - United States: Additions, revisions to Export Administration Regulations (EAR) entity list

25 Sep - United States: Initial observations on round 4 of CAMT guidance in Notice 2023-64

25 Sep - United States: IRS provides tax relief for taxpayers in Maine and Massachusetts affected by Hurricane Lee

25 Sep - United States: Missouri (sales tax collection); North Carolina (sourcing rules); Tennessee (sales and use tax industrial machinery exemption); Washington State (manufacturing B&O tax)

25 Sep - United States: Per diem rates, substantiation of employee lodging, meals, incidentals (2023-2024)

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

21 Sep - United States: Claims court erred in applying hybrid legal standard conflating step transaction and economic substance doctrines (Federal Circuit)

21 Sep - Canada: Deadline to qualify for partial loan forgiveness extended to early 2024

21 Sep - Australia: Draft legislation to improve tax system

20 Sep - Belgium: Tax exemptions granted on certain “excess” profits constitute unlawful State aid (CJEU judgment)

20 Sep - China appeals WTO panel report finding Chinese duties on U.S. products retaliatory

20 Sep - India: Reassessment notice issued without approval was time barred (High Court decision)

20 Sep - India: Taxpayer entitled to refund of taxes paid on behalf of nonresident (High Court decision)

20 Sep - Kenya: Public consultation on draft transfer pricing rules

20 Sep - OECD: Comments on public consultation document on Amount B under Pillar One

20 Sep - Saudi Arabia: Public consultation on draft regulation for Zakat collection

20 Sep - Switzerland: Elimination of tariffs on industrial goods effective 1 January 2024

20 Sep - Thailand: New interpretation of foreign-sourced income brought into Thailand by Thai tax residents

20 Sep - UK: Taxpayer acting as principal and not agent for VAT purposes (First-tier Tribunal decision)

20 Sep - United States: IRS announces new work unit focused on large or complex passthrough entities to help with high-income compliance efforts

19 Sep - Denmark: Transfer pricing adjustments on intercompany transactions between oil and gas company and its subsidiaries upheld (Supreme Court decision)

19 Sep - Colombia: Suspension of certain implementing guidance under single-use plastic products tax (Supreme Tax Court decision)

19 Sep - Poland: Real estate tax imposed on fuel and gas dispensers (Supreme Administrative Court decision)

18 Sep - Belgium: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid (Constitutional Court decision)

18 Sep - France: Tax officials announce e-invoicing mandate would become effective in 2026

18 Sep - United States: Arkansas (proposed reduction in income tax rates); Florida (guidance on sales and use tax audit program); Kansas (reduction in corporate income tax rate); Oregon (guidance on P.L. 86-272); Tennessee (industrial machinery sales tax exemption)

15 Sep - United States: IRS request for comments on expanding tax certainty and issue resolution programs for business taxpayers

15 Sep - United States: IRS request for feedback on proposed changes to Form 6765, Credit for Increasing Research Activities

15 Sep - Bolivia: Extended deadline for certain taxpayers to present affidavits and pay tax for August 2023

15 Sep - UK: Employers may reclaim national insurance contributions on car allowances (Upper Tribunal decisions)

15 Sep - UK: Increased scrutiny of R&D tax incentive claims

15 Sep - Australia: New communications protocol for ATO objections

14 Sep - Australia: Tax refunds will no longer be deposited into non-authorised deposit-taking institutions

14 Sep - Greece: New reporting obligations for digital platform operators (DAC7)

14 Sep - United States: IRS announces moratorium on processing new employer retention credit claims

13 Sep - United States: Initial observations and analysis of Notice 2023-63 providing guidance on section 174

13 Sep - United States: IRS provides tax relief for taxpayers in Georgia affected by Hurricane Idalia

12 Sep - United States: FBAR filing deadline relief for persons affected by certain natural disasters (Hawaii wildfires and Hurricane Idalia)

12 Sep - KPMG report: Estimating an arm’s length range for North American retailers

12 Sep - Mexico: List of 196 registered foreign providers of digital services (as of 31 August 2023)

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

12 Sep - Czech Republic: Accommodation service versus lease of real estate for VAT purposes, and abuse of rights concept (municipal court decision)

12 Sep - Czech Republic: Tax deductibility of management services (Supreme Administrative Court decision)

11 Sep - Czech Republic: Guidance on application of VAT to gratuitous supplies of goods

11 Sep - Bulgaria: New reporting obligation for VAT-registered persons

11 Sep - Cambodia: Procedures for requesting input VAT credits and VAT refunds

11 Sep - India: Singaporean company entitled to treaty benefits on capital gains from transfers of shares of Indian companies (tribunal decision)

11 Sep - United States: Immediate recognition of income upon constructive transfer of intangible property in reorganization; Tax Court affirmed (First Circuit)

11 Sep - United States: California (marketplace facilitator law); California (mutual fund service provider sourcing rule); New Jersey (corporation business tax nexus); New York (broker-dealer sourcing rule)

8 Sep - United States: Guidance on application of section 174

8 Sep - United States: IRS announces all QI / WP / WT applications for 2023 must be submitted through QAAMS by October 27

8 Sep - United States: IRS announces new compliance effort focused on high-income individuals, partnerships, and large corporations

8 Sep - United States: Proposed regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives

7 Sep - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for August 2023

7 Sep - United States: BIS imposes penalty to resolve violations of antiboycott rules

7 Sep - United States: Extension of product exclusions, China Section 301 investigation

7 Sep - Nigeria: Country-by-country reporting rules not validly adopted and thus unenforceable (Tax Appeal Tribunal decision)

6 Sep - Nigeria: Transfer of taxpayer’s file between tax offices was illegal (Tax Appeal Tribunal decision)

6 Sep - United States: IRS opens application period for 2024 Compliance Assurance Process (CAP) program

6 Sep - United States: IRS provides tax relief for taxpayers in South Carolina affected by Hurricane Idalia

5 Sep - United States: IRS releases FAQ for pass-through entities for electronically filing Schedules K-2 and K-3 to report negative amounts

5 Sep - Poland: Insurance services not guarantee services subject to lump-sum tax (Supreme Administrative Court decision)

5 Sep - UK: Interest deductions on intra-group debt disallowed on grounds of unallowable purpose (Upper Tribunal decision)

5 Sep - UK: HMRC guidance on advance pricing agreements

1 Sep - KPMG report: Comments on public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

1 Sep - Cyprus: Submission of company income statements and self-employed with accounts due 31 March 2024

1 Sep - EU: Enhanced enforcement of VAT rules on non-resident digital economy businesses

1 Sep - Seychelles: Changes to transfer pricing rules

August 2023

31 Aug - United States: IRS provides tax relief for taxpayers in Florida affected by Hurricane Idalia

30 Aug - Channel Islands: Closure of FATCA and CRS reporting portal (Jersey)

30 Aug - Portugal: Public country-by-country reporting legislation approved

30 Aug - United States: Guidance on state and local tax refunds and other payments to individuals

30 Aug - United States: IRS provides tax relief for taxpayers in Alaska affected by flooding

29 Aug - United States: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

29 Aug - Netherlands: Draft legislation implementing public country-by-country reporting

29 Aug - Poland: Application of general anti-abuse rule; taxation of restricted stock; taxation of company conversion (Supreme Administrative Court decisions)

29 Aug - Poland: Extended deadline for tax on unrealized gains; guidance on capital duty

29 Aug - EU: Certain carbon border adjustment mechanism rules challenged before CJEU

29 Aug - Luxembourg: Beneficial ownership of trademark (court decision)

29 Aug - Spain: Burden of proving abuse of withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision)

29 Aug - United Kingdom: Policy paper on reporting obligations for digital platform operators (DAC7)

28 Aug - Anguilla: Suspension of tax information exchange with Russia and Belarus

25 Aug - United States: Guidance on new Roth catch-up requirement, including administrative transition period

25 Aug - United States: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2023)

25 Aug - Australia: 12-month pause for general practitioners payroll tax audits (New South Wales)

25 Aug - Bolivia: Deadline to implement online invoicing modalities postponed for fourth, fifth, and sixth groups of taxpayers

25 Aug - Canada: Updated FATCA and CRS guidance

25 Aug - United States: IRS updates 2023 Form 1042-S instructions

24 Aug - Mauritius: New income tax treaty with Hong Kong entered into force

24 Aug - United States: IRS updates FAQ extending penalty relief, Forms 1042 and 1042-S

24 Aug - United States: Fourth quarter update to IRS 2022-2023 Priority Guidance Plan

23 Aug - United States: Premium tax credit percentage table for 2024

23 Aug - Australia: ATO requesting information on corporate tax transparency data for large companies

23 Aug - Barbados: Further extension of FATCA and CRS filing deadline to 8 September 2023

23 Aug - Israel: Guidance on competent authority, mutual agreement, and bilateral APA procedures

23 Aug - Saint Vincent and the Grenadines: Further extension of FATCA and CRS reporting deadline to 25 August 2023

23 Aug - Tunisia: Instrument of ratification of MLI deposited with OECD

22 Aug - Poland: Tax-deductible costs; income from IP and credit default swaps (court decisions)

22 Aug - Saudi Arabia: Eighth wave of e-invoicing applicability

21 Aug - United States: IRS provides tax relief for taxpayers affected by wildfires in Hawaii

21 Aug - United States: No change to list of countries cooperating with international boycott

21 Aug - United States: Pennsylvania (lookback period for voluntary disclosure agreement program); Tennessee (employment services not subject to sales and use tax)

21 Aug - Korea: Customs value of goods imported from bonded area (Supreme Court decision)

21 Aug - Korea: Proposed amendments to transfer pricing and Pillar Two rules

18 Aug - Bolivia: Digital notification of administrative acts

18 Aug - UAE: Conditions for qualifying investment funds to be exempt from corporate tax

18 Aug - United States: Oil and gas—reference prices for 2023, inflation adjustment factor and phase-out for enhanced oil recovery credit

17 Aug - Bahrain: Economic substance filing window open from 13 August to 13 September 2023

17 Aug - Canada: Provincial sales tax annual information return due 31 August for online marketplaces (British Columbia)

16 Aug - Denmark: Increase in VAT audits of nonresident digital services providers

16 Aug - Denmark: Interest on corrections of VAT and excise duties for past periods effective 1 July 2023

16 Aug - Philippines: VAT refund guidelines

16 Aug - Poland: Mandatory e-invoicing legislation enacted

16 Aug - Poland: Tax on revenue from buildings; VAT treatment of preliminary land sale contract; social media barter contract (court decisions)

16 Aug - WTO panel report finds China’s additional duties on U.S. imports inconsistent with WTO agreement

16 Aug - United States: IRS provides tax relief for taxpayers in Illinois affected by storms

15 Aug - United States: IRS provides tax relief for taxpayers in Mississippi affected by storms

15 Aug - Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules

15 Aug - Dominican Republic: Draft rule on appointment of VAT and income tax withholding and collection agents

15 Aug - United States: Select financial product provisions in Biden Administration’s FY 2024 budget

14 Aug - Canada: Prescribed rates of interest for income tax, PLOI purposes (fourth quarter 2023)

14 Aug - KPMG report: Accelerated competent authority procedure can extend MAP resolutions to subsequent years

14 Aug - United States: New Jersey (convenience of employer rule); New York (corporate franchise tax); South Carolina (method of apportionment)

11 Aug - United States: Availability of administrative exemptions from requirement to file electronically

10 Aug - Barbados: Further extension of FATCA and CRS filing deadline to 11 August 2023

10 Aug - Korea: Tax reform proposal for 2023, changes to Pillar Two and transfer pricing documentation rules

10 Aug - United States: Guidance on environmental justice solar and wind capacity limitation

9 Aug - United States: Deduction for assumed deferred compensation liabilities not allowed when not paid; Tax Court affirmed (Seventh Circuit)

9 Aug - India: CRS clarifications

9 Aug - Mexico: Agreement for collection of lodging taxes (Nuevo Leon)

9 Aug - OECD: Cryptoasset reporting framework (CARF) updates and CRS amendments

9 Aug - Philippines: Scanned copies of expenses do not satisfy tax deductibility requirements

8 Aug - Mauritius: Tax amnesty program renewed

8 Aug - Poland: Costs of foreign posting; withholding on foreign payments; increased real estate tax (court decisions)

8 Aug - United States: Exaction related to employer mandate under Affordable Care Act is a tax for jurisdictional purposes (D.C. Circuit)

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

8 Aug - WTO panel reports on disputes between India and United States, mutually agreed solutions

7 Aug - Australia: Audit on ATO’s management of transfer pricing for related-party debt

7 Aug - Australia: Review of regulatory frameworks for tax services and large consulting, accounting, and auditing firms

7 Aug - Ghana: Direct and indirect tax administration provisions in 2023 mid-year budget review

7 Aug - India: Payments for cloud computing services not taxable royalties or fees for technical services under U.S. tax treaty (tribunal decision)

7 Aug - India: Reassessment notice based on contradictory advance ruling for another taxpayer was invalid (High Court decision)

7 Aug - UK: Guidance on corporation tax relief for cost of net-settled and cash cancelled employee share awards

7 Aug - United States: California (apportionment formula); Michigan (sales factor, taxation of digital goods); New Hampshire (deduction for disallowed interest); Ohio (oil and gas sales and use tax exemption)

4 Aug - United States: Guidance on qualification of home energy audits for energy efficient home improvement credit under section 25C

4 Aug - United States: Guidance on section 5000D excise tax on sales of “designated drugs”

4 Aug - Belgium: Overview of APA system

4 Aug - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for July 2023

4 Aug - Croatia: Implementation of public country-by-country reporting

4 Aug - EU: Formal notice to 14 member states of failure to implement public country-by-country reporting

4 Aug - EU: Reasoned opinion to six member states on failure to fully transpose DAC7

4 Aug - Hong Kong: Latest proposals on tax certainty scheme for onshore equity disposal gains and expanded foreign-sourced income exemption regime

4 Aug - Hungary: Formal notice of failure to align corporate income tax rules with ATAD

4 Aug - Italy: Taxpayer not respected as beneficial owner of interest payments (Supreme Court decision)

4 Aug - Luxembourg: Referral to CJEU by European Commission for failure to correctly transpose ATAD interest limitation rules

4 Aug - UAE: Implementation of new tax procedures executive regulation

3 Aug - United States: Draft forms provide insight into compliance burden imposed by new CAMT

3 Aug - United States: Monetized installment sale transactions identified as listed transactions

3 Aug - KPMG report: Amount B and tax certainty

3 Aug - Sri Lanka: Extended due date for filing quarterly advance income tax statements

2 Aug - South Africa: Proposed APA program

1 Aug - Bolivia: Online billing modality for “fourth group of taxpayers” further postponed

1 Aug - Bolivia: Online billing modality for “fifth group of taxpayers” postponed

1 Aug - Poland: Recordkeeping for IP Box relief; cash as tax-deductible cost; residential property used in business; taxation of agricultural prizes (Supreme Administrative Court decisions)

1 Aug - Australia: ATO Corporate Plan focuses on collectible debts

1 Aug - Bulgaria: Amendments to beneficial owners registry law

1 Aug - Germany: Updated CRS guidance, final state exchange list

1 Aug - United States: Validating Form W-8BEN and BEN-E treaty claims

July 2023

31 Jul - EU: Public country-by-country reporting implementation summary

31 Jul - Korea: Amendments to “Method 4” for determining customs value

31 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Canada and Mexico

31 Jul - Saudi Arabia: Seventh wave of e-invoicing applicability

31 Jul - United States: California (sales tax audit methods); New Jersey (convenience of employer rule); Oklahoma (franchise tax returns): Texas (franchise tax reports)

31 Jul - United States: Cryptocurrency rewards included in income when taxpayer gains dominion and control over rewards

28 Jul - United States: IRS clarifies position on employee retention credit supply chain disruptions (generic legal advice memorandum)

28 Jul - France: Delay in e-invoicing and e-reporting implementation

28 Jul - Kenya: KRA must issue objection decision within 60 days (court decision)

28 Jul - Portugal: Updated FATCA and CRS user manuals

28 Jul - Vietnam: Expediting VAT refunds

27 Jul - United States: IRS request for comments on dispute resolution programs

27 Jul - United States: Accounting for income taxes considerations for foreign tax credits following Notice 2023-55

27 Jul - United States: Legal expenses for defending patent infringement suits are deductible (Third Circuit)

27 Jul - Bahrain: VAT return filing and payment deadline extended to 1 August 2023

27 Jul - Luxembourg: VAT treatment of activities carried out by board member (CJEU Advocate General opinion)

26 Jul - United States: CBP adjusts customs user fees for inflation (FY 2024)

26 Jul - United States: Procedures for voluntarily self-disclosing violations of U.S. sanctions and export control laws

26 Jul - Saudi Arabia: Penalty waiver for taxes, including VAT and excise tax, extended through December 2023

25 Jul - KPMG report: New guidance on Pillar Two rules, initial observations and analysis

25 Jul - KPMG report: Public consultation on Amount B under Pillar One, initial observations

25 Jul - KPMG report: OECD’s effort to simplify transfer pricing

25 Jul - United States: IRS TE/GE division provides four new technical guides

25 Jul - United States: Percentage depletion for oil and gas produced from marginal properties; electricity production credit

24 Jul - United States: California (tax on lease of tangible personal property); Mississippi (computer software direct pay permits)

24 Jul - UK: Transfer pricing records regulations published

24 Jul - Ireland: Updated FATCA, CRS guidance for AEOI

24 Jul - Japan: Updated FAQs under CRS regime

21 Jul - Antigua and Barbuda: FATCA, CRS reporting deadlines extended to 19 September 2023

21 Jul - Australia: Determination on GST, wine tax, luxury car tax for defence-related international obligations

21 Jul - Korea: Payments treated as expenses under cost sharing agreement and not royalties (Administrative Court decision)

21 Jul - Malaysia: Guideline for implementation of e-invoicing

21 Jul - United States: Temporary relief for foreign tax credit under sections 901 and 903

20 Jul - KPMG report: Latest Pillar Two guidance provides some relief for U.S. multinationals, but concerns remain

20 Jul - Singapore: Profits method used to value property for property tax purposes

19 Jul - United States: 90-day time limit to file deficiency petition is not jurisdictional and thus subject to equitable tolling (Third Circuit)

19 Jul - Australia: Draft instrument on correcting fuel tax errors

19 Jul - Dominican Republic: Draft law modifying tax assessment, audit and payment procedures

19 Jul - Luxembourg: U.S. branch denied permanent establishment status (administrative court decision)

19 Jul - Poland: Preferential corporate rate; residential depreciation repeal; deductibility of certain expenses (Supreme Administrative Court decisions)

19 Jul - South Africa: Updated PAYE administrative penalties

19 Jul - UAE: FATCA, CRS risk assessment questionnaire user guide

18 Jul - United States: Letters sent inviting companies to join unclaimed property voluntary disclosure agreement program, 90 days to respond (Delaware)

18 Jul - Australia: Guidance on claiming research and development tax incentives

18 Jul - United States: Additions to Export Administration Regulations (EAR) entity list

18 Jul - United States: Underutilization of alternative dispute resolution programs

17 Jul - United States: Manufacturer of defense weapon systems and defense contractor agree to settle violations of antiboycott regulations

17 Jul - Germany: CRS reporting deadline extended to 31 August 2023

17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules

17 Jul - OECD: Public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

14 Jul - United States: Transition relief and guidance related to certain required minimum distributions

14 Jul - United States: Notice of filing of petition for addition of methyl ethyl ketoxime to Superfund list

13 Jul - France: New transfer pricing measures announced for 2024 Draft Finance Bill

13 Jul - Thailand: Guidance for taxpayers within scope of Pillar Two global minimum tax rules

13 Jul - India: Payments on account of seconded employees not taxable as "fees for technical services" (tribunal decision)

13 Jul - Saudi Arabia: Guidelines on tax rulings

13 Jul - United States: IRS practice unit: Expatriation on or after 17 June 2008—mark-to-market tax regime

13 Jul - United States: IRS provides tax relief for taxpayers in Vermont affected by flooding

13 Jul - KPMG report: Implications of the Inflation Reduction Act and CHIPS Act for U.S. importers

12 Jul - EU: European Commission progress report on Pillar One

12 Jul - Germany: Draft bill implementing Pillar Two global minimum tax

12 Jul - Italy: Withholding tax on dividends paid to investment fund breaches EU law, refund granted (court decision)

12 Jul - Latvia: Updated list of non-cooperative jurisdictions

12 Jul - Liechtenstein: Consultation on implementation of public country-by-country reporting

12 Jul - Malta: Guidance on DAC7

12 Jul - Netherlands: Proposed amendments to tax ruling policy

12 Jul - OECD: Outcome statement on BEPS 2.0

12 Jul - UK: HMRC removes requirement for UK companies to make annual country-by-country reporting notification

11 Jul - Barbados: FATCA and CRS filing deadline extended to 2 August 2023

11 Jul - Canada: New mandatory disclosure rules clarified

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

11 Jul - Nigeria: Extended deadline for filing companies income tax returns for 2023

11 Jul - Poland: Mobile application for e-invoicing; consultation on schemas for digital platform operators (DAC7)

11 Jul - South Africa: Further information required on section 18A donation receipts

10 Jul - United States: Carryback of consolidated net operating losses

10 Jul - Australia: Taxpayer’s “food” product subject to GST (Administrative Appeals Tribunal decision)

10 Jul - Australia: Procedural rules for digital games tax offset; regulations to enable compensation scheme of last resort; regulations for new registrable superannuation entity reporting requirements 

10 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Germany, the Netherlands, and Sweden

10 Jul - Mexico: Guidance on social security tax practices

10 Jul - Oman: Income tax treaty with Egypt signed

10 Jul - Panama: List of reportable jurisdictions updated for 2023

10 Jul - UK: No UK taxing rights under UK-Canada treaty on UK oil field production profits paid to non-resident (Court of Appeal judgment)

7 Jul - Brazil: Public consultation on new transfer pricing rules

7 Jul - Luxembourg: Updated FAQ on mandatory disclosure rules (DAC6)

7 Jul - Philippines: Running of prescriptive period for VAT, applicability of VAT to interest income from affiliated loans (Supreme Court decision)

7 Jul - Poland: Definition of structure for real estate tax purposes held unconstitutional (Constitutional Tribunal decision)

7 Jul - Spain: Deadline to claim VAT refunds for 2022 is 30 September 2023

7 Jul - South Africa: Persons required to submit third party returns

6 Jul - United States: Section 41 research tax credit denied, accuracy-related penalties imposed (U.S. Tax Court)

6 Jul - United States: Partnership losses claimed on unsigned, unfiled tax returns disallowed; Tax Court reversed (Ninth Circuit)

6 Jul - Australia: Report on review of advance pricing agreement program

6 Jul - Australia: Research and development tax incentives claim denied (Federal Court decision)

6 Jul - India: Guidance on withholding tax on purchases of overseas tour packages and foreign remittances

6 Jul - Ireland: Extension of FATCA and CRS filing deadline

5 Jul - Australia: Updated guidance on residency central management and control test, including new risk-free assessment framework

5 Jul - Chile: U.S. income tax treaty approved by U.S. Senate

5 Jul - India: Capital gain exempt under Singapore treaty (High Court decision)

3 Jul - United States: Period of limitations for assessing tax on partnership items expired (U.S. Tax Court)

June 2023

30 Jun - United States: Distributive shares of partnership income from sale of partnership assets is patronage-sourced income (PLR)

30 Jun - India: Tax residency certificate for claiming tax treaty benefits; tax withheld at source under liberalised remittance scheme and overseas tour program package

30 Jun - UAE: Updated FATCA, CRS guidance and policy manual

29 Jun - Bolivia: “Fifth group of taxpayers” to implement online billing modality

29 Jun - Panama: CRS reporting deadline extended to 15 August 2023

29 Jun - Philippines: Distributions on depository receipts taxed as interest, not dividends

29 Jun - Romania: Amendments to public country-by-country reporting rules

29 Jun - United States: Taxpayers not required to report or pay stock repurchase excise tax before time specified in forthcoming regulations

28 Jun - Australia: Draft guidance on interaction of non-arm’s length income and capital gains, control and residency tests

28 Jun - France: Implementation of public country-by-country reporting

28 Jun - Germany: Updated transfer pricing guidelines; U.S. agreement on automatic exchange of country-by-country reporting

28 Jun - Lithuania: Country-by-country reporting directive transposed into domestic law

28 Jun - Luxembourg: Guidance on reverse hybrid rules

28 Jun - OECD: Updated guidelines for multinational enterprises, final cryptoasset reporting framework rules

28 Jun - Poland: Reducing depreciation during period of State aid not tax evasion; invoices issued prematurely not fictitious

28 Jun - United States: Coordinated export control enforcement (Australia, Canada, New Zealand, United Kingdom, United States)

27 Jun - United States: Analysis and observations of direct pay and transferable credit proposed regulations

27 Jun - Australia: Overhead costs apportioned to GST-free supplies entitled to input tax credits (Federal Court decision)

27 Jun - Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax

27 Jun - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (June 2023)

27 Jun - OECD: Tax transparency in Latin America 2023

26 Jun - Australia: Delay in implementation of public country-by-country (CbC) reporting

26 Jun - Belgium: Income tax treaty with Netherlands signed

26 Jun - KPMG report: Transfer pricing methods for asset management sub-advisers

26 Jun - UK: Consultation on transfer pricing, permanent establishment, and DPT rules

26 Jun - UK: Deduction denied for payments on related-party indebtedness (First-tier Tribunal decision)

26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested

26 Jun - UK: Updated guidance on anti-avoidance rules for creative sector tax reliefs

26 Jun - United States: Alabama (monthly sales tax filing threshold); Michigan (memo not a request for refund); Texas (sales and use tax exemptions); Washington State (data processing)

26 Jun - United States: Foreign tax credit—categorization of income and taxes into proper basket

26 Jun - United States: State, local tax changes (second quarter 2023, table format)

26 Jun - United States: Supreme Court grants certiorari, whether mandatory repatriation tax under section 965 is constitutional

23 Jun - United States: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2023

23 Jun - United States: Guidance related to COVID-19 for purposes of high-deductible health plans

23 Jun - United States: Reference price for enhanced oil recovery credit, marginal oil and gas production

23 Jun - United States: Value of anticipated cash grants are separate intangible assets for purchase price allocation purposes (U.S. Court of Federal Claims)

23 Jun - Chile: Extension of deadline for filing transfer pricing affidavits

23 Jun - Costa Rica: Updated list of cross-border digital service providers

23 Jun - Korea: Imported plastic toys that can be assembled and disassembled subject to 0% tariff rate (Tax Tribunal decision)

23 Jun - Korea: Imputation of arm’s length interest on accounts receivable from foreign affiliate was reasonable (Tax Tribunal decision)

21 Jun - KPMG reports: Transfer pricing considerations in mergers and acquisitions, focus on UK

21 Jun - OECD: Continued progress on harmful tax practices

21 Jun - Poland: Invoices issued prematurely not fictitious; documentation of business in special economic zone (Supreme Administrative Court decisions)

21 Jun - Poland: Reduced VAT on food extended; mandatory e-invoicing; revocation of state of health emergency

21 Jun - Saudi Arabia: Criteria for sixth group of taxpayers to comply with second phase of e-invoicing implementation

21 Jun - Switzerland: Implementation of Pillar Two minimum tax approved by public vote

21 Jun - United States: JCT analysis of possible effects of Pillar Two global minimum tax adoption

21 Jun - United States: National Taxpayer Advocate mid-year report to Congress identifying key objectives for upcoming fiscal year

21 Jun - United States: Passthrough net operating loss carryovers disallowed due to insufficient basis (U.S. Tax Court)

21 Jun - United States: Senate votes to invoke cloture on income tax treaty with Chile

20 Jun - Australia: Consultation on non-arm’s length income provisions amendments

20 Jun - EU: European Commission proposal to improve withholding tax procedures

20 Jun - Hong Kong: Advance rulings under foreign-sourced income exemption regime

20 Jun - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on France, Italy, and Spain

20 Jun - KPMG report: Transfer pricing considerations for ESG-related intangible assets

20 Jun - Luxembourg: Instructions related to TIN field issued

20 Jun - South Korea: Revised CRS regulations

20 Jun - Spain: Draft e-invoicing regulations published

16 Jun - EU: ECOFIN report addressing “Unshell” Directive, DAC8, automatic exchange of information

16 Jun - Chile: Obligation to issue tax receipts for all transactions, regardless of amount

16 Jun - Norway: Draft legislation implementing Pillar Two minimum tax

16 Jun - Poland: Interest required to be paid on unduly withheld taxes (CJEU judgment)

15 Jun - Poland: Amendments to simplify and accelerate VAT settlements, including “Slim 3 VAT package”

15 Jun - Poland: Revenue from business in special economic zone; deduction of VAT in cross-border transactions and residential leases (Supreme Administrative Court decisions)

15 Jun - Australia: Overview on key FY 2022-2023 changes for tax professionals

15 Jun - Australia: Requirements of recipient created tax invoice for GST purposes

15 Jun - Brazil: OECD-aligned transfer pricing rules signed by president

15 Jun - Canada: Budget 2023 general anti-avoidance rule consultation, KPMG comments

15 Jun - Netherlands: Denial of dividend withholding tax exemption under anti-abuse provision upheld (CJEU Advocate General opinions)

15 Jun - United States: Updated annual list of automatic accounting method changes

15 Jun - United States: Updated guidance on requirements for energy community production and investment tax credits

14 Jun - United States: Treasury and IRS release guidance on direct pay and transferable tax credits

14 Jun - British Virgin Islands: Revised updates on reporting U.S. TIN codes for FATCA purposes

14 Jun - Cyprus: Deadline for filing date of individual’s tax return, self-assessment extended to 2 October 2023

14 Jun - Denmark: Public country-by-country reporting legislation passed

14 Jun - Nigeria: Federal Inland Revenue Service empowered to appoint non-resident suppliers as agents of VAT collection (Tax Appeal Tribunal)

14 Jun - Saint Vincent and the Grenadines: Extended FATCA and CRS reporting deadline

14 Jun - Singapore: High Court dismisses appeal, holds that cement silo is not a “plant” for capital allowance purposes

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

13 Jun - Italy: Updated FATCA, CRS technical guidance

13 Jun - Kenya: Declaration of related-party or controlled transactions on income tax company returns

13 Jun - Saudi Arabia: Proposed amendments to tax and Zakat regulations for public consultation purposes

13 Jun - UAE: Updated FATCA, CRS system registration user guide

12 Jun - Canada: Consultation on proposed transfer pricing rules

12 Jun - Hong Kong: Changes to issuance of certificate of residence status and application forms

12 Jun - Hong Kong: Update on profits tax, BEPS 2.0, and e-filing

12 Jun - KPMG report: Brazil’s proposed transfer pricing rules, implications for intercompany financial transactions

12 Jun - Liechtenstein: Updated FATCA guidance concerning U.S. TINs

12 Jun - UK: Importance of commercial reality in assessing withholding tax obligations (Upper Tribunal decision)

12 Jun - UK: New accruals framework for carried interest

12 Jun - UK: Treasury “call for evidence” on employee save-as-you-earn and share incentive plans

12 Jun - United States: Connecticut (corporate surcharge extension); Illinois (investment partnership status changes); Louisiana (sales tax economic nexus threshold change); Mississippi (no good faith basis for exempt sales); Oklahoma (franchise tax repealed)

12 Jun - United States: Revisions to Export Administration Regulations (EAR) entity list

12 Jun - United States: Tax treatment of employer-funded, fixed-indemnity insurance policy (Chief Counsel legal advice memo)

12 Jun - United States: Treasury, OMB agreement no longer requires OIRA review for tax regulatory actions issued by IRS

9 Jun - United States: Organizations developing NIL opportunities for student-athletes generally will not qualify as tax-exempt

9 Jun - United States: Ways and Means Chairman Smith releases three tax bills

9 Jun - Australia: Final ruling regarding deductibility of labor costs relating to capital assets

9 Jun  - Cambodia: New law on taxation

9 Jun - Saint Kitts and Nevis: FATCA and CRS reporting deadline extended to 29 August 2023

8 Jun - Canada: QST annual information return for distribution platform operators due 30 June (Quebec)

8 Jun - Canada: Mutual agreement procedure (MAP) statistics for 2021

8 Jun - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU Advocate General opinion)

7 Jun - United States: “Country of origin” ruling affects U.S. importers

7 Jun - United States: Estimated tax penalty relief for corporations subject to CAMT

7 Jun - United States: Foreign tax credit issues arising from 2022 Colombian tax reform

7 Jun - KPMG report: Transfer pricing implications of automotive innovation

6 Jun - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for May 2023

6 Jun - Dominican Republic: Law creating national tax system of electronic invoicing passed

6 Jun - France: New proposals to counter international tax fraud, including lower turnover threshold for transfer pricing documents

6 Jun - Germany: Interim findings and outcomes from mandatory disclosure rules (DAC6) reporting

6 Jun - Luxembourg: Draft law implementing DAC7

6 Jun - Malaysia: FAQs on re-implementation of voluntary disclosure programs

6 Jun - Spain: Bill implementing DAC7 enacted, implications for financial institutions

6 Jun - Spain: Foreign alternative investment fund entitled to refund of dividend withholding tax (Supreme Court decision)

6 Jun - United States: State nil reporting and penalty notices

6 Jun - United States: Malta personal retirement scheme transactions identified as listed transactions

5 Jun - United States: Colorado (commercial property tax valuations); Minnesota (retail delivery fee); Nebraska (corporate income tax rate reduction); Virginia (manufacturer’s apportionment formula)

5 Jun - United States: President Biden signs bill to increase debt limit, partially rescind IRS funding

5 Jun - United States: President Biden to nominate Marjorie Rollinson as IRS Chief Counsel

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

5 Jun - United States: Value of stock held by estate included life insurance proceeds intended for redemption of such stock (Eighth Circuit)

5 Jun - British Virgin Islands: No penalties for late filings due to BVIFars technical difficulties

2 Jun - Israel: Tax authority’s claim of deemed taxable transfer of functions, assets, and risks upheld (court decision)

2 Jun - United States: Senate passes bill to increase debt limit, partially rescind IRS funding; President Biden to sign

1 Jun - Malaysia: Transfer pricing and advance pricing arrangement rules 2023

1 Jun - St. Lucia: Updated FATCA TIN guidance

1 Jun - United States: House passes bill to increase debt limit, partially rescind IRS funding

May 2023

31 May - United States: Additional guidance on qualifying advanced energy project credit under section 48C(e)

31 May - Poland: New reporting requirements for cross-border payment service providers beginning 2024

31 May - Saudi Arabia: Fifth wave of e-invoicing applicability

30 May - Saudi Arabia: Annual audit certification for FATCA and CRS reporting due 1 August 2023

30 May - Dominican Republic: Updated FATCA TIN codes

30 May - Luxembourg: Parliament passes bill to implement DAC7, affecting CRS

30 May - Philippines: Optional filing and payment of monthly VAT returns for VAT-registered persons

30 May - Tanzania: Retained earnings of resident company subject to withholding tax (Tax Revenue Appeals Board decision)

30 May - UK: Definition of “structure” for capital allowance purposes (Supreme Court decision)

30 May - UK: No time limit for seeking judicial review of adverse income tax credit determination (Court of Appeal decision)

30 May - UK: Update on mandatory disclosure rules (DAC6), now effective

26 May - Nigeria: Federal Inland Revenue Service empowered to collect withholding tax as advance payment of income tax (Tax Appeal Tribunal)

26 May - Singapore: Application of GST in “direct selling” business model (High Court decision)

25 May - Germany: Expenses for rental of moveable and immoveable assets may be subject to trade tax (Federal Tax Court decision)

25 May - Germany: Losses of permanent establishments in other EU countries not deductible (Federal Tax Court decision)

25 May - Hong Kong: Voluntary e-filing of profits tax returns

25 May - India: Clarification of FATCA TIN code update

25 May - Mexico: Obligation to present tax opinion to Infonavit

25 May - United States: Guidance regarding expansion of employee plans compliance resolution system under Secure Act 2.0

25 May - United States: House Ways and Means Chairman Smith introduces bill that would impose additional tax on foreign jurisdictions with undertaxed payments rule (UTPR)

25 May - United States: IRS announces tax relief for taxpayers affected by Typhoon Mawar (Guam and Northern Mariana Islands)

24 May - United States: Finance, Ways and Means chairs and ranking members write letter to Treasury and IRS regarding Secure Act 2.0 technical corrections

24 May - United States: IRS expanding determination letter program to include certain section 403(b) plans

24 May - Bolivia: Online billing modality for “fourth group of taxpayers” postponed

24 May - EU: Update on DAC7 implementation (May 2023)

24 May - Poland: E-invoicing legislation submitted to lower house of Parliament

24 May - Poland: Excise duty on exported passenger cars not contrary to EU principles (CJEU judgment)

24 May - Poland: Insurance not subject to lump-sum income tax; scope of economic zone exemption (Supreme Administrative Court decisions)

24 May - Spain: Bill implementing DAC7; VAT, income tax, and FATCA implications for finance and insurance industries

23 May - Costa Rica: Declaration by inactive legal entities due 31 May

23 May - India: Sales tax on warranty replacements; GST on rummy; taxation of receipt of shares for inadequate consideration (court decisions)

23 May - Korea: Prices of imports and exports were not manipulated to benefit third parties (court decision)

23 May - Korea: Software installation fee is royalty subject to withholding tax under income tax treaty (Tax Tribunal decision)

22 May - British Virgin Islands: Economic substance guidance for entities claiming tax residence in Jersey, Guernsey, or Isle of Man

22 May - Egypt: Decree issued for change in income tax and VAT regulations

22 May - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on United States and UK

22 May - United States: Application of the FIRPTA regularly traded exception to stock held by partnerships (Chief Counsel legal advice memo)

22 May - United States: Domestic content bonus credit guidance under Notice 2023-38

22 May - United States: Gift tax assessment time-barred (updated with KPMG observations) (U.S. Tax Court)

22 May - United States: Interest rates, tax underpayments and overpayments remain same for third quarter 2023

22 May - United States: Minnesota (omnibus tax package); Montana (bill to exclude tax haven entities); Tennessee (tax changes enacted)

22 May - United States: Treatment of captive insurance arrangements as insurance companies for tax purposes

19 May - Australia: Updated draft practical compliance guideline on intangibles arrangements

19 May - Denmark: Beneficial ownership for purposes of withholding tax exemption for cross-border interest payments (court decision)

19 May - EU: Action seeking annulment of EU minimum tax directive (EU General Court)

19 May - EU: Agreement on DAC8 compromise text (EU Council)

19 May - France: Tax integration scheme held incompatible with EU freedom of establishment (CJEU judgment)

19 May - Saint Vincent and the Grenadines: Deadline for reporting CRS and FATCA returns is 31 May 2023

19 May - United States: Final rule implementing additional sanctions against Russia and Belarus

19 May - United States: Russia-related guidance includes general licenses, directive, determinations, and FAQs

19 May - United States: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers upheld (U.S. Supreme Court)

18 May - Singapore: Determining the true nature of payments in a transaction

18 May - South Africa: Reporting period for FATCA, CRS third-party data annual submissions process

18 May - Spain: Differential treatment runs contrary to free movement of capital for foreign, domestic non-UCITS funds (Supreme Court decision)

17 May - EU: Proposed reform of EU Customs Union

17 May - Switzerland: Transfer pricing topics of focus in audits and ruling requests

17 May - United States: BIS issues temporary denial order suspending export privileges of companies and individuals for attempts to divert electronics and aircraft parts to Russia

17 May - United States: Expenses under orphan drug credit under section 45C must also be taken in account in determining research credit under section 41 (U.S. Tax Court)

16 May - United States: Accountable care organization not entitled to tax exemption under section 501(c)(4) (U.S. Tax Court)

16 May - United States: Cost of goods sold includes only excise taxes actually paid in determining excise tax liability (U.S. Tax Court)

16 May - United States: HSA inflation-adjusted amounts for 2024

16 May - United States: IRS report on potential free e-filing system; pilot program for 2024 filing season

16 May - Channel Islands: FATCA and CRS reporting deadline is 30 June 2023 (Guernsey)

16 May - EU: New tax transparency rules for service providers facilitating cryptoasset transactions

16 May - Indonesia: Overview of transfer pricing environment

16 May - Poland: Deduction limitation applies to company’s car rental payments (Supreme Administrative Court decision)

16 May - United States: Interest expense limitations under sections 267(a)(3) and 163(j); dividend distribution with a debt

16 May - South Africa: VAT registration process becomes more stringent

15 May - South Africa: Enhancements to tax compliance status process

15 May - United States: Colorado (retail delivery fee); Florida (federal conformity, sales and use tax); Indiana (corporate income tax, sales and use tax)

15 May - United States: Taxation of paid or reimbursed travel expenses and determination of employee’s tax home

12 May - United States: USTR extension of product exclusions, China Section 301 investigation

12 May - Germany: FATCA reporting deadline is 31 July 2023

12 May - Bulgaria: No adjustment of input VAT deductions for scrapped or destroyed goods (CJEU judgment)

12 May - Cyprus: New format of tax identification number

12 May - South Africa: VAT numbers declared on customs documents monitored

12 May - UAE: New transfer pricing documentation requirements

12 May - United States: Domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E

12 May - United States: JCT overview of federal tax system (2023)

11 May - Brazil: OECD-aligned transfer pricing rules passed by Senate

11 May - Czech Republic: Sale of land treated as sale of goods for VAT purposes; no reverse charge for supplies of moveable items (Supreme Administrative Court decisions)

11 May - OECD: Public consultation on toolkits to support developing countries in addressing BEPS risks when pricing minerals

11 May - UK: Update to CRS reportable jurisdictions list

10 May - Malta: One-time concession on administrative penalties for failure to file recapitulative statements for VAT

10 May - Switzerland: Prior tax year losses allowed against real estate gains (Federal Supreme Court decision)

10 May - Poland: Council of Ministers adopt mandatory e-invoicing draft law

10 May - United States: JCT report on U.S. international taxation of U.S. multinationals, ahead of Senate Finance hearing

10 May - United States: KPMG analysis of IRS 2022 APA statistics

10 May - United States: Maryland Supreme Court dismisses challenge to digital advertising tax

10 May - United States: “Qualified research” test under section 41, summary judgment denied (U.S. Tax Court)

9 May - United States: Information reporting and transfer for valuable consideration rules for section 1035 exchanges

9 May - India: Long-term capital gains on sale of unlisted shares; attribution of profit; place of supply of intermediary services (court decisions)

9 May - Netherlands: New guidance on mandatory disclosure rules (DAC6)

9 May - Poland: Compatibility with EU law of tax exemption for real estate forming part of railway infrastructure (CJEU referral)

8 May - Mexico: Updated procedures to obtain opinion on compliance with social security tax obligations

8 May - KPMG report: Progress on improving mutual agreement procedure

8 May - United States: Third quarter update to IRS 2022-2023 Priority Guidance Plan

5 May - Romania: Tax rules for purely domestic mergers not required to be interpreted consistently with EU law (CJEU judgment)

5 May - United States: IRS provides tax relief for taxpayers in California affected by February storms

5 May - United States: Issuance of Russia-related general license, authorizing transactions related to energy

4 May - Belgium: Referral by European Commission to CJEU for failure to properly transpose CFC rules under ATAD

4 May - France: Foreign tax credit on foreign-source dividends cannot exceed corporate income tax paid on such dividends (Supreme Court decision)

4 May - Luxembourg: European Commission erred in finding grant of State aid (CJEU Advocate General opinion)

4 May - Malta: Updated FAQs with further clarifications on DAC6 notice requirements for intermediaries

4 May - Philippines: Online submission of annual tax incentives and benefits reports

4 May - Spain: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation suspended (Supreme Court decision)

4 May - United States: Request for recommendations for IRS 2023-2024 Priority Guidance Plan

3 May - United States: COVID-19 disaster relief payments under section 139

3 May - United States: IRS announces QI / WP / WT application and account management system (QAAMS) fully transitioning to new sign-in system

3 May - United States: Receipt of profits interest in partnership in exchange for services not taxable (U.S. Tax Court)

3 May - Italy: Withholding tax on dividends paid to U.S. collective investment funds breaches EU law (court decision)

2 May - Cambodia: Clarification of rules regarding when withholding tax is due

2 May - Saudi Arabia: Fourth wave of e-invoicing applicability

2 May - Singapore: FATCA and CRS return filing due 31 May 2023

2 May - United States: IRS provides tax relief for taxpayers in Florida affected by tornadoes, severe storms, and flooding

1 May - United States: Arizona (sales tax processing exemption); Michigan (delivery and installation charges subject to sales or use tax); Tennessee (excise and franchise tax changes pending enactment)

1 May - United States: IRS guidance on review and acceptance of APA submissions

1 May - UK: Business premises renovation allowances not allowed (Court of Appeal decision)

1 May - UK: Tax policy and consultation documents on modernizing, simplifying and improving the tax system

April 2023

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

28 Apr - Canada: Expanded mandatory reporting obligations

28 Apr - Germany: Corporate income tax applicable to nonresident closed-end real estate funds held incompatible with EU law (CJEU judgment)

28 Apr - Spain: New reporting requirements for cross-border payment service providers beginning 2024

28 Apr - United States: IRS Commissioner Werfel testifies at House Ways and Means Committee hearing on accountability and transparency at the IRS

27 Apr - Cyprus: Update on income tax treaty with the Netherlands

27 Apr - Estonia: Date on which taxable payment from equity determined in cross-border merger of companies (Supreme Court decision)

27 Apr - Germany: Expenses for rental of trade fair stand not subject to trade tax (federal tax court decision)

27 Apr - Saint Kitts and Nevis: AEOI compliance form guidelines

26 Apr - Barbados: AEOI portal opens for 2022 submissions in May

26 Apr - India: New direct and indirect tax dispute settlement scheme (West Bengal)

26 Apr - India: Rate of dividend distribution tax may not be reduced under applicable treaty (tribunal decision)

26 Apr - Nigeria: Extended VAT filing deadline following updates to features for VAT filing and payment on online platform

26 Apr - Singapore: Digital service to view status of FATCA and CRS returns

25 Apr - France: E-invoicing and digital reporting pilot program beginning January 2024

25 Apr - United States: International tobacco company agrees to pay $508 million to settle violations of sanctions against North Korea and weapons of mass destruction proliferators

25 Apr - Colombia: Updated electronic invoicing regulations

25 Apr - Peru: Updates to CRS reporting deadlines

25 Apr - Thailand: Draft legislation requiring automatic exchange of information (AEOI)

25 Apr - Uruguay: Updated CRS submission details

24 Apr - Cyprus: Extension of deadline for VAT returns

24 Apr - India: Amnesty program for non-compliance of export obligations

24 Apr - India: Determination of arm’s length prices by Tribunal subject to review by High Courts (Supreme Court decision)

24 Apr - Korea: Criteria for selection of comparable companies (Tax Tribunal decision)

24 Apr - Korea: Customs penalty upheld even though taxpayer voluntarily amended customs value (Tax Tribunal decision)

24 Apr - Nigeria: Guidelines on process of generating electronic tax clearance certificate (Lagos State)

24 Apr - Nigeria: Updated features for VAT filing and payment on online platform

24 Apr - United States: Effect of IRS funding on information reporting

24 Apr - United States: Colorado (effect of CARES Act); Missouri (sales and use tax manufacturing exemption); Virginia (federal conformity)

24 Apr - United States: IRS provides tax relief for taxpayers in Oklahoma affected by storms, straight-line winds, and tornadoes

21 Apr - Thailand: Requirements for e-tax invoice

20 Apr - Canada: Extension of manufacturing and processing exporter tax incentive (Saskatchewan)

20 Apr - EU: European Commission adopts DAC7 for exchange of information with non-EU countries

20 Apr - EU: European Economic and Social Committee adopts supportive opinion on DAC8 proposal

20 Apr - Finland: Instructions for missing U.S. TINs for FATCA purposes

20 Apr - India: Withdrawal of GST exemption for passenger transportation services booked through electronic platform upheld (high court decision)

20 Apr - Italy: Draft legislation for implementation of DAC7

20 Apr - Lithuania: Draft legislation implementing public country-by-country reporting

20 Apr - Nigeria: State infrastructure maintenance and development levies enforced (Tax Appeal Tribunal decision)

20 Apr - Spain: Withholding tax on royalties must be on net basis (court decision)

20 Apr - United States: Annuity payments received from charitable remainder trusts taxable as ordinary income (U.S. Tax Court)

20 Apr - United States: Foreign insurance companies; effectively connected net investment income (2022)

19 Apr - United States: IRS Commissioner Werfel testifies at Senate Finance Committee hearing on 2024 IRS budget and IRS’s 2023 filing season

19 Apr - United States: Technology export controls for automated peptide synthesizers

19 Apr - Mongolia: Commitment to start automatic exchange of information (AEOI) by 2026

18 Apr - Spain: Constitutional challenge to temporary solidarity tax on large fortunes

18 Apr - Mexico: Increase in lodging tax rate for certain tourist accommodation services (State of Guerrero)

18 Apr - United States: JCT report on energy-related tax changes made by “Inflation Reduction Act of 2022”

18 Apr - United States: IRS provides tax relief for taxpayers in Indiana affected by tornadoes and severe storms

18 Apr - United States: Order renewing—for a second time—temporary denial of export privileges of Russian airline

17 Apr - United States: Arkansas (corporate rate reduction, throwback rule phase out); Kentucky (definition of telemarketing services); Washington State (B&O deduction for investment income)

17 Apr - EU: WTO case on India’s tariffs on information and communication technology products

17 Apr - Poland: Dividends paid to foreign related entity subject to withholding tax (court decision)

17 Apr - Saudi Arabia: Amendments to transfer pricing bylaws

14 Apr - Luxembourg: Draft legislation on APAs and MAP procedures, transfer pricing documentation requirements, and general tax procedures

14 Apr - Czech Republic: Compensation paid to electricity and gas suppliers subject to VAT

14 Apr - Czech Republic: Deductibility of advertising costs (Supreme Administrative Court decisions)

14 Apr - Czech Republic: Updated information on tax assessment obligations of accommodation service providers

14 Apr - United States: IRS releases tax collection data for fiscal year 2022

14 Apr - United States: Safe harbor method of accounting for expenses related to natural gas transmission and distribution property

13 Apr - Cayman Islands: Updated FATCA and CRS deadlines

13 Apr - Philippines: Online registration and update system introduced

13 Apr - United States: Initial observations on Notice 2023-29 guidance on determining energy communities for IRA tax credits

12 Apr - United States: Prior ruling relating to expensing of research and experimentation expenditures obsolete

12 Apr - United States: Additions and revisions to Export Administration Regulations (EAR) entity list

12 Apr - KPMG report: Transfer pricing and ESG—public tax strategies and tax transparency

12 Apr - Poland: Limit on deductibility for costs of intangible services; deductibility of expenses relating to opening event (Supreme Administrative Court decisions)

12 Apr - Poland: New binding rate information template

12 Apr - South Africa: Additional disclosure requirements for trusts

11 Apr - Australia: Draft legislation for public country-by-country (CbC) reporting

11 Apr - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for March 2023

11 Apr - United States: Expansion of defense articles and services eligible for transfer under Canadian and treaty exemptions

10 Apr - United States: Colorado (notice of tax credits to employees); Georgia (federal tax conformity); New Mexico (tax package vetoed); West Virginia (apportionment changes)

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

10 Apr - United States: Rules for supervisory approval of penalties

7 Apr - United States: Revised Form 3115 for applications for change in accounting method

7 Apr - Saudi Arabia: Third wave of e-invoicing applicability

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

6 Apr - Bahamas: Economic substance legislation and guidance notes introduced

6 Apr - Canada: Reminder of 30 April 2023 deadline, tax on cross-border insurance

6 Apr - Switzerland: Reminder of 30 June 2023 deadline to claim VAT refunds

6 Apr - United States: IRS releases strategic operating plan for use of IRA funds

5 Apr - United States: Foreign taxes paid on accumulated earnings offset under section 965 are creditable (federal district court)

5 Apr - Estonia: Guidance on tax defensive measures relating to non-cooperative jurisdictions

5 Apr - Honduras: FATCA reporting deadline extended to 30 April 2023

5 Apr - India: Fees for technical services and royalties under treaties; grounds for denying refund (court decisions)

4 Apr - Bolivia: Modernization of registration procedures and modification to national digital biometric taxpayer register

4 Apr - EU: Updated State aid guiding templates

4 Apr - Mexico: Payroll electronic invoice 4.0 (CFDI 4.0) mandatory beginning 1 July 2023 (three-month extension)

4 Apr - Philippines: Guidance on return processing system assessment notices

4 Apr - Poland: Deductibility of interest on late payments; depreciation by real estate companies (court decisions)

4 Apr - Poland: Municipality installing renewable energy systems and removing asbestos not subject to VAT (CJEU judgment)

4 Apr - Spain: Updated FATCA FAQs concerning U.S. TINs

4 Apr - United States: Guidance on requirements for energy community production and investment tax credits under IRA

3 Apr - United States: Extension of transition period for single-country exception documentation requirement under section 903

3 Apr - United States: IRS lacks statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471 (U.S. Tax Court)

3 Apr - United States: IRS provides tax relief for taxpayers in Arkansas affected by tornadoes and severe storms

3 Apr - United States: Kentucky (sales and use tax); Mississippi (changes related to section 174); Mississippi (sales tax treatment of computer software); Washington State (capital gains tax is permissible excise tax)

3 Apr - Bahrain: Penalties applied to unregistered businesses charging VAT on supplies

3 Apr - UK: Mandatory disclosure rules (DAC6) effective

March 2023

31 Mar - Brazil: OECD-aligned transfer pricing rules passed by Chamber of Deputies, await vote in Senate

31 Mar - Canada: Penalty, interest relief for late-filed underused housing tax returns

31 Mar - United States: Guidance on new clean vehicle credit

30 Mar - Serbia: Rulebook on arm’s length interest rates for 2023

30 Mar - Spain: Services performed by Spanish branch for foreign head office not subject to VAT (National High Court decision)

30 Mar - Sweden: Foreign tax credit carryforward allowed on income not subject to foreign tax

30 Mar - United States: OFAC issues amended Russia-related FAQ, “exit tax” payment prior to divestment of assets located in Russia

29 Mar - United States: APMA program, APA statistics for 2022

29 Mar - United States: No basis step-up for assets of irrevocable grantor trust not included in grantor’s estate

29 Mar - Poland: Deadline for corporate income tax filings extended to 30 June 2023

29 Mar - Poland: Limitation period for tax liabilities (COVID-19); R&D costs; real estate tax (Supreme Administrative Court decisions)

29 Mar -  South Africa: New dispute resolution rules

29 Mar - Germany: Shareholder not entitled to challenge assessment against corporation (federal tax court decision)

28 Mar - Germany: Taxation of profits from cryptocurrencies (federal tax court decision)

28 Mar - Poland: New bill on mandatory use of national e-invoicing system

28 Mar - United States: IRS provides tax relief for taxpayers in Mississippi affected by tornadoes and severe storms

27 Mar - Sweden: Draft legislation implementing public country-by-country reporting presented to parliament

27 Mar - Switzerland: New goods traffic system for digital processing of customs procedures

27 Mar - UK: Parliament passes Australia-UK free trade agreement legislation

27 Mar - United States: Clarification of date on which substances added or removed from Superfund list

27 Mar - United States: IRS guidance on electronic filing of Form 8038-CP for bond issuers requesting tax credit payments

27 Mar - United States: Superfund excise taxes, extension of relief regarding failure to deposit penalties

24 Mar - United States: IRS provides tax relief for taxpayers in New York affected by winter storms, snowstorms

24 Mar - United States: Beneficial ownership information reporting guidance

24 Mar - United States: Rule amending Belarus Sanctions Regulations

23 Mar - United States: Revisions to “unverified list”

23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax

23 Mar - Greece: Updated lists of non-cooperative jurisdictions and preferential tax regime countries

23 Mar - Malta: Clarifications on DAC6 notification requirements for intermediaries

22 Mar - Bahrain: Mandatory digital stamps for waterpipe tobacco products

22 Mar - Belgium: Draft legislation modernizing “VAT chain” passed by Chamber of Representatives

22 Mar - Bolivia: Online billing modality for “fourth group of taxpayers”

22 Mar - Spain: Public consultation on Pillar Two global minimum tax

22 Mar - United States: IRS provides revised FAQs on Form 1099-K

21 Mar - United States: Guidance and request for comments on treatment of certain NFTs as section 408(m) collectibles

21 Mar - Australia: Draft legislation requiring disclosure of subsidiaries' tax residence in financial reports

21 Mar - Chile: Tax treatment of expenses and donations associated with catastrophes; VAT development

21 Mar - Montenegro: Amendments to tax law include changes to Local file requirements

21 Mar - Qatar: Income tax treaty signed with Egypt

20 Mar - India: Proof required for claiming input VAT credit (Supreme Court decision)

20 Mar - Korea: Tax authority entitled to re-assess arm’s length interest rate on related-party loan (Tax Tribunal decision)

20 Mar - Korea: Advance customs valuation arrangement, coordination with transfer pricing

20 Mar - UK:  Group relief provision compatible with EU law (Court of Appeal judgment)

20 Mar - United States: California (unclaimed property); Colorado (real estate sales and receipts factor); Florida (costs of performance sourcing rule); Louisiana (sales and use tax informational report); Montana (single receipts factor)

17 Mar - United States: Charitable deduction denied, donor must realize capital gains shares sold by donee (U.S. Tax Court)

17 Mar - United States: IRS provides tax relief for taxpayers in California affected by March storms, flooding, landslides, mudslides

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

17 Mar - United States: USTR adequately responded to remand in case challenging tariffs on imports from China (U.S. trade court)

17 Mar - Cyprus: Mandatory use of single tax portal for VAT payments

17 Mar - Indonesia: New customs and VAT obligations on imported software products, other digital goods

17 Mar - Mexico: Figure of “compensation” not a payment of VAT (court decision)

17 Mar - United States: Crypto crackdown—information reporting in a digital asset world

17 Mar - United States: FASB proposed accounting standards update addresses requests for improved tax disclosures

17 Mar - United States: IRS provides FAQs on whether nutrition, wellness, and general health costs are medical expenses

16 Mar - OECD: Public consultation meeting on implementation under Pillar Two

15 Mar - Poland: Extended deadline for submitting ORD-U reports

15 Mar - Poland: Scope of debt financing expenses; taxation of cross-border employee (Supreme Administrative Court decisions)

15 Mar - United States: Guidance concerning unclaimed property voluntary compliance program (California)

15 Mar - United States: ITC report on implication of sections 232 and 301 tariffs on imports

15 Mar - United States: Notice of filing of petition for addition of cellulose acetate (degree of substitution = 1.5 – 2.0) to Superfund list

14 Mar - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2024 budget

14 Mar - Channel Islands: Guidance on updates to U.S. TIN reporting obligations (Guernsey)

14 Mar - India: Transfer pricing rules apply if counterparty becomes associated enterprise in same tax year (tribunal decision)

14 Mar - United States: Housing expense limit adjustments, foreign locations for 2023

14 Mar - United States: Proposed regulations concerning Superfund chemical tax and Superfund imported substance tax; OIRA review completed

13 Mar - Czech Republic: Ownership of goods for VAT purposes (Supreme Administrative Court decision)

13 Mar - India: Salaries of seconded employees; extension of time for reassessment notices; tax residency certificates (court decisions)

13 Mar - Nigeria: Joint tax audit and investigation team (Lagos State)

13 Mar - Saudi Arabia: Public consultation on draft amendments to Zakat implementing regulations

13 Mar - United States: Minnesota (sales tax guidance for marketplace providers); Texas (apportionment for franchise tax); Wisconsin (online ticket marketplace liable for sales and use tax)

13 Mar - United States: Waiver for individuals electing to exclude foreign earned income

13 Mar - United States: Werfel sworn in as new IRS Commissioner

10 Mar - United States: IRS acquiescence to Fifth Circuit decision, tax on exports of domestic crude oil held unconstitutional

10 Mar - United States: Tax return not considered filed when sent in response to IRS inquiry; Tax Court affirmed (Ninth Circuit)

10 Mar - Cyprus: Frequently asked questions on transfer pricing documentation rules

10 Mar - Czech Republic: Updated list of non-cooperative jurisdictions

10 Mar - France: Ruling on withholding tax on dividend equivalent payments

10 Mar - Kenya: VAT on exported services is standard rated at 16% (court decision)

10 Mar - Luxembourg: Draft legislation for implementation of public country-by-country reporting

10 Mar - Mauritius: Disclosure of U.S. TINs in FATCA returns

10 Mar - Netherlands: Ruling on permanent establishment issues when employees work from home

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

9 Mar - South Africa: Ten-year extension of R&D tax incentive announced

9 Mar - United States: Credit for production of electricity from advanced nuclear power facilities under section 45J

9 Mar - United States: FY 2024 budget: “Green Book”—Treasury’s explanation of tax proposals

9 Mar - United States: Indexing adjustments for amounts used to calculate employer shared responsibility payments

9 Mar - United States: Senate confirms Werfel to be IRS Commissioner

8 Mar - KPMG report: Transfer pricing implications of intercompany fees for internal carbon pricing

8 Mar - Canada: Rephrased source of income test (court decision)

8 Mar - Mexico: Extension for submission of informative returns

8 Mar - Netherlands: Deduction of interest not limited in active group financing companies (Supreme Court decision)

8 Mar - Vietnam: Directives on tax inspections and tax audits for 2023

7 Mar - Bolivia: Extended deadline for certain taxpayers to register in VAT sales and purchases registry for February 2023

7 Mar - Poland: Public consultation on transfer pricing cost-plus method regulations

7 Mar - Poland: Tax-deductible costs in revenue and expense ledgers; mutual trademark transactions

7 Mar - United States: Relief for reporting required minimum distributions for 2023

7 Mar - United States: Research tax credit disallowed, Tax Court affirmed

6 Mar - United States: District of Columbia (sales tax on resold items); multistate (escheatment of abandoned property); multistate (corporate surtaxes)

6 Mar - Cyprus: Extension of time for objecting to tax assessment notices

6 Mar - Hong Kong: Instrument of ratification of MLI deposited with OECD

3 Mar - Poland: Obligation to disclose interests in real estate companies applies to non-residents

2 Mar - United States: Finance Committee advances Werfel to be next IRS Commissioner

1 Mar - Germany: Reduction of the basis for assessment of VAT due to irrecoverable debts, other VAT developments

1 Mar - KPMG report: Recent U.S. Trade Court decision on customs “origin”

February 2023

28 Feb - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU judgment)

28 Feb - United States: IRS reminder of 1 March deadline for farmers or fishers not making quarterly estimated tax payments

28 Feb - United States: Penalty for FBAR violation applies on per-report, not per-account basis (U.S. Supreme Court)

27 Feb - Brazil: Guidance on new OECD-aligned transfer pricing rules

27 Feb - Germany: Summary of recent federal tax court decisions

27 Feb - Italy: Withholding tax on dividends paid to investment fund breaches EU law (court decision)

27 Feb - Poland: Scope of tax rulings; due diligence obligation of tax remitters (Supreme Administrative Court decisions)

27 Feb - Poland: VAT exclusion for supply of undertaking or organized part thereof (CJEU judgment)

27 Feb - United States: Corporate Alternative Minimum Tax considerations and FAQs (updated after Notices 2023-7 and 2023-20)

27 Feb - United States: Electronic-filing requirements for exempt organization returns, other returns and documents

27 Feb - United States: Mississippi (decoupling from section 174); Pennsylvania (income-producing activity test); Washington State (capital gains excise tax); multistate (federal tax conformity)

27 Feb - United States: Relief with respect to lookback periods for returns with postponed due dates

24 Feb - United States: IRS provides tax relief for “disaster area taxpayers” in Alabama, California, Georgia

24 Feb - Belgium: Qualitative evaluation of whether renovations constitute new construction for VAT purposes required (court decision)

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

24 Feb - Malta: Electronic filing of VAT returns and payments due 22 February 2023 extended to 28 February 2023

24 Feb - Malta: One-year extension of allowance to transfer unabsorbed capital allowances intra-group

24 Feb - United States: Guidance on Section 301 duties and product exclusions (imports from China)

24 Feb - United States: Proposed regulations concerning information returns of cryptocurrency brokers; OIRA review completed

23 Feb - United States: Final versions of Form 5500 series, annual employee benefit plan reports

23 Feb - United States: “Benefits-received” interpretation of income-producing activity test upheld (Supreme Court decision)

23 Feb - Mexico: Rules for issuance of tax compliance opinion (Nuevo Leon)

23 Feb - Philippines: Letter of authority required to vest authority in new revenue officer (Supreme Court resolution)

23 Feb - UK: Group transfer rules not contrary to EU law (CJEU judgment)

22 Feb - Australia: Updated U.S. TIN codes for FATCA purposes

22 Feb - South Africa: Guidance providing clarification for FATCA reporting TIN codes

21 Feb - Denmark: New automatic check of reported VAT figures

21 Feb - Mexico: Agreement to facilitate payroll tax withholding (Nuevo Leon)

21 Feb - Poland: Definition of “joint venture”; deductibility of employment contract termination costs (court decisions)

21 Feb - Poland: Draft decree would extend deadline for 2022 corporate income tax returns to 30 June 2023

21 Feb - Spain: Publication of list of non-cooperative jurisdictions

21 Feb - United States: Electronic-filing requirements for specific tax returns, other documents

21 Feb - United States: Observations from Notice 2023-20 (guidance regarding certain insurance related issues under corporate alternative minimum tax)

20 Feb - United States: California (unclaimed brokerage accounts); Louisiana (cloud-based storage plans not subject to sales tax); Louisiana (manufacturing machinery and equipment sales tax exclusion); Tennessee (deduction for FDII)

20 Feb - United States: Observations from Notice 2023-18 (guidance on qualifying advanced energy project credit under section 48C)

20 Feb - Korea: Customs and VAT valuation of “free samples” provided under supply contract (Supreme Court decision)

20 Feb - Korea: Tax authority not entitled to select only certain local distributors for transfer pricing adjustment (Tax Tribunal decision)

20 Feb - Nigeria: Network facilities providers not subject to National Information Technology Development Agency (NITDA) levy (Tax Appeal Tribunal decision)

20 Feb - UK: Guidance under new mandatory disclosure rules

20 Feb - UK: Overview of employer-financed retirement benefit schemes and related compliance obligations

17 Feb - United States: Interim guidance regarding certain insurance related issues under corporate alternative minimum tax (CAMT)

16 Feb - Brazil: Changes in tax disputes resolution system

16 Feb - India: Vouchers not subject to GST; “risky exporter” entitled to GST refund; dismissal held improper (court decisions)

16 Feb - OECD: Comments on public consultation documents on implementation under Pillar Two

15 Feb - OECD: New toolkit to strengthen effective collection of VAT on e-commerce in Africa

15 Feb - Armenia: Commitment to start automatic exchange of information (AEOI) by 2025

15 Feb - Ireland: Summaries of FATCA and CRS reporting requirements

15 Feb - UK: HMRC transfer pricing and diverted profits tax statistics for year ended 31 March 2022

14 Feb - United States: Link for renewal of QI agreements now live

14 Feb - Czech Republic: Abuse of law concept, documentation of expenses for related-party services (regional court decisions)

14 Feb - EU: Updates to list of non-cooperative jurisdictions (four added to “black list”, revisions to “grey list”)

14 Feb - Ghana: Mandatory online filing of individual income tax returns

14 Feb - KPMG report: Changes to Brazilian transfer pricing and royalty deduction rules, implications for U.S. multinationals

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

14 Feb - Poland: Extended deadline for 2022 corporate income tax returns

13 Feb - United States: IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program

13 Feb - United States: IRS guidance on state tax refunds, general welfare and disaster relief payments

13 Feb - United States: Guidance on environmental justice solar and wind capacity limitation under section 48(e)

13 Feb - United States: Guidance on qualifying advanced energy project credit under section 48C

13 Feb - United States: Interest rates, tax underpayments and overpayments remain same for second quarter 2023

13 Feb - United States: Minnesota (retail delivery fee); Missouri (resale tax exemption); multistate (taxation of digital products and services and software)

13 Feb - Sweden: Proposal for implementation of public country-by-country reporting

10 Feb - Finland: Updated FATCA reporting requirements

9 Feb - Bolivia: Extended deadline for certain taxpayers to register in purchases and sales registry

9 Feb - Canada: Prescribed rates of interest for income tax, PLOI purposes (second quarter 2023)

9 Feb - India: Tax residency certificate sufficient evidence of residency under India-Singapore income tax treaty (high court decision)

9 Feb - KPMG report: Administrative guidance on the GloBE rules, focusing on issues of importance to U.S. companies

9 Feb - UK: Updated FATCA reporting guidance

9 Feb - United States: Regulation under section 482 relating to consideration of foreign legal restrictions upheld (U.S. Tax Court)

8 Feb - Mauritius: Taxation of variable capital companies

8 Feb - United States: Updates on third six-year remedial amendment cycle for pre-approved defined benefit plans

7 Feb - Canada: New underused housing tax (UHT) filing, payment due 30 April

7 Feb - EU: Access to documents of EU Council working groups on public country-by-country reporting (EU General Court)

7 Feb - Romania: New reporting obligations for digital platform operators (DAC7)

7 Feb - United States: Gain recognized on sale of partnership interest attributable to inventory may be U.S.-source income (U.S. Tax Court)

6 Feb - United States: Arizona (transaction privilege tax); Michigan (rolling stock use tax exemption); Texas (sourcing of local sales tax on internet orders); Wisconsin (nonconformity with section 174 changes)

6 Feb - United States: Guidance on implementation of Russia-origin petroleum products price cap policy

6 Feb - Poland: Guidance for real estate companies, deductibility of intangible services costs incurred by acquired subsidiary (court decisions)

6 Feb - Poland: VAT rate ambiguities interpreted in taxpayers’ favor; “Slim VAT 4 package” announced

6 Feb - Qatar: Amendment of transfer pricing-related provisions of Income Tax Law for 2018

6 Feb - Switzerland: Overview and case study of administrative assistance procedure under income tax treaties

3 Feb - Argentina: Guidance for taxpayers to mitigate freely available balances in income tax collection regime

3 Feb - Bolivia: Extended deadline for online billing modality, Form 510 submission and payment

3 Feb - Netherlands: Interest on corporate income tax and withholding tax to increase to 10.5%

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

3 Feb - United States: Service industry tip compliance agreement program

3 Feb - United States: Updated FAQs for clean vehicle credit under section 30D

2 Feb - OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules

2 Feb - Poland: Mandatory e-invoicing postponed until 1 July 2024

2 Feb - Spain: State aid determination annulled because aid recipients were erroneously identified (CJEU judgment)

1 Feb - Malta: Updated automatic exchange of information (AEOI) implementing guidelines

1 Feb - Nigeria: Federal Inland Revenue Service only authority for assessment and collection of taxes (court decision)

1 Feb - OECD: Manual on handling of mutual agreement procedures (MAPs) and advance pricing arrangements (APAs)

January 2023

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

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

31 Jan - Ghana: Inauguration of Independent Tax Appeals Board

31 Jan - Serbia: New practice regarding collection of tax

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

19 Jan - Cyprus: New single tax administration portal

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

17 Jan - Philippines: Monthly VAT declaration no longer required

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

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

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

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

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

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

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

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

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

11 Jan - EU: Update on DAC7 implementation

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

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

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

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

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

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

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

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

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

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

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

10 Jan - United States: House passes IRS defunding bill

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

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

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

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

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

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

5 Jan - Germany: Updated CRS guidance

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

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

3 Jan - Poland: Interest rates for transfer pricing purposes

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

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

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

2022 Articles

December 2022

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

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

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

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

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

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

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

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

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

29 Dec - United States: Standard mileage rates for 2023

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

20 Dec - UAE: New transfer pricing rules

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

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

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

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

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

16 Dec - EU: Council adopts EU minimum tax directive

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

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

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

15 Dec - Hungary: Guidance on transfer pricing reporting

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

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

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

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

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

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

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

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

13 Dec - EU: VAT gap statistics for 2020

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

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

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

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

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

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

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

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

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

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

9 Dec - UK: Income tax treaty with Brazil signed

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

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

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

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

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

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

7 Dec - United States and Croatia sign income tax treaty

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1 Dec - Finland: Clarifications on DAC7 reporting obligations

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

November 2022

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

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

30 Nov - Italy: New rules on import VAT recovery

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

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

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

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

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

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

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

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

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

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

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

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

28 Nov - Qatar: Transfer pricing documentation requirements

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

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

22 Nov - Malta: Formal transfer pricing rules published

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

16 Nov - Denmark: DAC7 guidance

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

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

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

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

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

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

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

14 Nov - Montenegro: Guidance under new transfer pricing rules

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

8 Nov - Philippines: Guidance on electronic filing email notification

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

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

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

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

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

3 Nov - FinlandDraft legislation to implement DAC7

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

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

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

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

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

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

2 Nov - Saudi Arabia: Application of Zakat regulations

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

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

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

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

October 2022

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

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

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

31 Oct - United States: Combined federal state filing program

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

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

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

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

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

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

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

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

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

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

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

25 Oct - Poland: Updated transfer pricing reporting obligations guidebook

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

18 Oct - Bahrain: Preparing for VAT field audits

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4 Oct - Philippines: Guidelines and procedures for requesting MAP

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

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

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

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

September 2022

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

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

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

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

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

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

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

29 Sep - Puerto Rico: Tax-related hurricane relief

29 Sep - South Africa: Increased transfer pricing scrutiny

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

August 2022

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

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

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

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

29 Aug - Poland: Transfer pricing measures in draft bill

26 Aug - Bulgaria: MLI ratified

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

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

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

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

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

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

25 Aug - Finland: Updated FATCA and CRS FAQs

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2 Aug - Bolivia: Guidance concerning tax payment facilities

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

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

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

July 2022

29 Jul - Lithuania: Changes to APA rules

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

27 Jul - OECD: Progress on harmful tax practices

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

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

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

26 Jul - Bolivia: Revised tax administrative and procedure measures

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

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

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

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

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

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

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

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

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

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

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

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)

 

Tax Dispute Resolution Quarterly

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

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

Read the Spring 2023 Tax Dispute Resolution Quarterly

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.