Recent Articles
October 2023
September 2023
29 Sep - Slovakia: Guidance on proving identity of beneficial owner of income
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: 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 - 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 - 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 - 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: Per diem rates, substantiation of employee lodging, meals, incidentals (2023-2024)
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 - 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)
19 Sep - Poland: Real estate tax imposed on fuel and gas dispensers (Supreme Administrative Court decision)
18 Sep - France: Tax officials announce e-invoicing mandate would become effective in 2026
15 Sep - Bolivia: Extended deadline for certain taxpayers to present affidavits and pay tax for August 2023
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 - 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: 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
8 Sep - United States: Guidance on application of section 174
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
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 - UK: HMRC guidance on advance pricing agreements
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
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 - Netherlands: Draft legislation implementing public country-by-country reporting
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 - 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 - 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 - 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 - 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
17 Aug - Bahrain: Economic substance filing window open from 13 August to 13 September 2023
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 - 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 - 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)
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 - 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 - 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 - Ghana: Direct and indirect tax administration provisions in 2023 mid-year budget review
4 Aug - United States: Guidance on section 5000D excise tax on sales of “designated drugs”
4 Aug - Belgium: Overview of APA system
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 - 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 - 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 - 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 - Saudi Arabia: Seventh wave of e-invoicing applicability
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: 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 - 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
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 - Malaysia: Guideline for implementation of e-invoicing
21 Jul - United States: Temporary relief for foreign tax credit under sections 901 and 903
20 Jul - Singapore: Profits method used to value property for property tax purposes
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 - South Africa: Updated PAYE administrative penalties
19 Jul - UAE: FATCA, CRS risk assessment questionnaire user guide
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 - Germany: CRS reporting deadline extended to 31 August 2023
17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules
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 - 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 - 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
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 - 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 - 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
7 Jul - Brazil: Public consultation on new transfer pricing rules
7 Jul - Luxembourg: Updated FAQ on mandatory disclosure rules (DAC6)
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 - 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 - 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 - 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
28 Jun - France: Implementation of public 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
27 Jun - United States: Analysis and observations of direct pay and transferable credit proposed regulations
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: Foreign tax credit—categorization of income and taxes into proper basket
26 Jun - United States: State, local tax changes (second quarter 2023, table format)
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 - Chile: Extension of deadline for filing transfer pricing affidavits
23 Jun - Costa Rica: Updated list of cross-border digital service providers
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: Reduced VAT on food extended; mandatory e-invoicing; revocation of state of health emergency
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: 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: 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 - 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 - United States: Updated annual list of automatic accounting method changes
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 - Denmark: Public country-by-country reporting legislation passed
14 Jun - Saint Vincent and the Grenadines: Extended FATCA and CRS reporting deadline
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 - Liechtenstein: Updated FATCA guidance concerning U.S. TINs
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: Revisions to Export Administration Regulations (EAR) entity list
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
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 - Dominican Republic: Law creating national tax system of electronic invoicing passed
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 - 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: 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 - British Virgin Islands: No penalties for late filings due to BVIFars technical difficulties
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 - UK: Definition of “structure” for capital allowance purposes (Supreme Court decision)
30 May - UK: Update on mandatory disclosure rules (DAC6), now effective
26 May - Singapore: Application of GST in “direct selling” business model (High 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
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)
23 May - Costa Rica: Declaration by inactive legal entities due 31 May
23 May - Korea: Prices of imports and exports were not manipulated to benefit third parties (court decision)
22 May - Egypt: Decree issued for change in income tax and VAT regulations
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: Treatment of captive insurance arrangements as insurance companies for tax purposes
19 May - Australia: Updated draft practical compliance guideline on intangibles arrangements
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
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
17 May - EU: Proposed reform of EU Customs Union
17 May - Switzerland: Transfer pricing topics of focus in audits and ruling requests
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 - South Africa: VAT registration process becomes more stringent
15 May - South Africa: Enhancements to tax compliance status process
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 - UK: Update to CRS reportable jurisdictions list
10 May - Poland: Council of Ministers adopt mandatory e-invoicing draft law
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 - Netherlands: New guidance on mandatory disclosure rules (DAC6)
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 - United States: IRS provides tax relief for taxpayers in California affected by February storms
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 - United States: Request for recommendations for IRS 2023-2024 Priority Guidance Plan
3 May - United States: COVID-19 disaster relief payments under section 139
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
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 - Spain: New reporting requirements for cross-border payment service providers beginning 2024
27 Apr - Cyprus: Update on income tax treaty with the Netherlands
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 - 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 - 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 - Korea: Criteria for selection of comparable companies (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
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 - Italy: Draft legislation for implementation of DAC7
20 Apr - Lithuania: Draft legislation implementing public country-by-country reporting
20 Apr - Spain: Withholding tax on royalties must be on net basis (court decision)
20 Apr - United States: Foreign insurance companies; effectively connected net investment income (2022)
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”
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 - 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
13 Apr - Cayman Islands: Updated FATCA and CRS deadlines
13 Apr - Philippines: Online registration and update system introduced
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: 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
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 - Estonia: Guidance on tax defensive measures relating to non-cooperative jurisdictions
5 Apr - Honduras: FATCA reporting deadline extended to 30 April 2023
4 Apr - EU: Updated State aid guiding templates
4 Apr - Philippines: Guidance on return processing system assessment notices
4 Apr - Spain: Updated FATCA FAQs concerning U.S. TINs
3 Apr - Bahrain: Penalties applied to unregistered businesses charging VAT on supplies
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 - Sweden: Foreign tax credit carryforward allowed on income not subject to foreign tax
29 Mar - United States: APMA program, APA statistics for 2022
29 Mar - Poland: Deadline for corporate income tax filings extended to 30 June 2023
29 Mar - South Africa: New dispute resolution rules
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
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: Superfund excise taxes, extension of relief regarding failure to deposit penalties
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 - 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: Advance customs valuation arrangement, coordination with transfer pricing
20 Mar - UK: Group relief provision compatible with EU law (Court of Appeal judgment)
17 Mar - United States: IRS TE/GE division provides two new technical guides
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
16 Mar - OECD: Public consultation meeting on implementation under Pillar Two
15 Mar - Poland: Extended deadline for submitting ORD-U reports
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
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 - United States: Housing expense limit adjustments, foreign locations for 2023
13 Mar - Czech Republic: Ownership of goods for VAT purposes (Supreme Administrative Court decision)
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: Waiver for individuals electing to exclude foreign earned income
13 Mar - United States: Werfel sworn in as new IRS Commissioner
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: FY 2024 budget: “Green Book”—Treasury’s explanation of tax proposals
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 - Vietnam: Directives on tax inspections and tax audits for 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 - 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 - 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)
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: VAT exclusion for supply of undertaking or organized part thereof (CJEU judgment)
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 - Channel Islands: No change in deadline for FATCA and CRS reporting (Guernsey)
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)
23 Feb - United States: Final versions of Form 5500 series, annual employee benefit plan reports
23 Feb - Mexico: Rules for issuance of tax compliance opinion (Nuevo Leon)
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: 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
20 Feb - UK: Guidance under new mandatory disclosure rules
20 Feb - UK: Overview of employer-financed retirement benefit schemes and related compliance obligations
16 Feb - Brazil: Changes in tax disputes resolution system
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 - Ghana: Mandatory online filing of individual income tax returns
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 qualifying advanced energy project credit under section 48C
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 - UK: Updated FATCA reporting guidance
8 Feb - Mauritius: Taxation of variable capital companies
7 Feb - Canada: New underused housing tax (UHT) filing, payment due 30 April
7 Feb - Romania: New reporting obligations for digital platform operators (DAC7)
6 Feb - United States: Guidance on implementation of Russia-origin petroleum products price cap policy
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
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
1 Feb - Malta: Updated automatic exchange of information (AEOI) implementing guidelines
January 2023
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: 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 - Spain: Public consultation on changes to criteria for non-cooperative jurisdictions
27 Jan - KPMG report: Comments on public consultation on new common corporate tax system in the EU (BEFIT)
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 - Poland: Guidance on partnership merger, transformation (Supreme Administrative Court decisions)
24 Jan - Nigeria: Deadline for employer’s filing PAYE tax returns is 31 January 2023
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 - UK: Consultation on R&D tax relief reform
23 Jan - UK: Final mandatory disclosure rules (DAC6) regulations published
20 Jan - United States: IRS extends due date for QI withholding agreement to 1 May 2023
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: 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)
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 - 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 - 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
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: “Time to pay” arrangements to help mitigate liquidity challenges
5 Jan - Germany: Updated CRS guidance
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
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: Proposed regulations concerning electronically filed returns; OIRA review completed
29 Dec - United States: Standard mileage rates for 2023
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 - 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 - 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 - 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 - 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: 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 - 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 - 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
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 - Kenya: Minimum tax on gross turnover is unconstitutional (court decision)
6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda
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
5 Dec - Belgium: Reform of periodic VAT returns, debts
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
November 2022
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
29 Nov - United States: Interest rates, tax underpayments and overpayments (increase for first quarter 2023)
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 - Panama: “Extraordinary payment agreements” for tax obligations
28 Nov - Qatar: Transfer pricing documentation requirements
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: 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)
18 Nov - United States: Guidance relating to the foreign tax credit (text of regulations)
17 Nov - OECD: Aggregated country-by-country reporting data
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 - Netherlands: VAT recovery based on bank’s “actual use method” (Supreme Court decision)
14 Nov - Montenegro: Guidance under new transfer pricing rules
14 Nov - Panama: Benefits granted under “SEM Visa” not unconstitutional (Supreme Court decision)
11 Nov - Bolivia: Fourth group of taxpayers required to issue tax documents through online billing modality
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 - Netherlands: Concept of “essentially a new building” for VAT purposes (Supreme Court decision)
10 Nov - United States: President Biden to nominate Daniel Werfel as IRS Commissioner
9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)
8 Nov - Philippines: Guidance on electronic filing email notification
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 - Finland: Draft legislation to implement DAC7
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
1 Nov - Poland: Government approves extension of excise tax exemption for plug-in electric vehicles
October 2022
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
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 - 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: Trade tax treatment of dividend from dual resident corporation (tax court decision)
26 Oct - Qatar: Guidance on submission of no-objection certificate
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
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 - Romania: Bill implementing public country-by-country (CbC) reporting directive
20 Oct - South Africa: Guidance on definition of “associated enterprises” under transfer pricing rules
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)
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
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 - 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: Penalties on unified annual reconciliation of apportionable income (Washington State)
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 - 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
September 2022
30 Sep - Belgium: Guidance on VAT refund procedures and remunerations in football
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: Changes to customs importer of record rules, implications for e-commerce importers
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)
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 - United States: Excess loss account included in income of consolidated group member (U.S. Tax Court)
22 Sep - Finland: Withholding tax refunds for Luxembourg SICAV funds
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 - 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: Updated Technical Guide on exemption of certain business leagues and boards
16 Sep - United States: Unclaimed property voluntary compliance program legislation enacted (California)
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
12 Sep - Spain: Deadline to claim VAT refunds for 2021 is 30 September 2022
9 Sep - United States: Guidance relating to IRS Independent Office of Appeals (text of proposed regulations)
6 Sep - UK: Updated HMRC guidance on making tax digital for income tax self-assessment
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 - Finland: Mandatory disclosure rules (DAC6) reporting assessment published
26 Aug - OECD: Peer review reports on transparency and exchange of information on request
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
24 Aug - United States: Penalty relief for certain taxpayers filing returns for tax years 2019 and 2020
24 Aug - Germany: Law amending interest on back taxes and tax refunds effective 22 July 2022
24 Aug - Ireland: Updated reporting entity registration form for FATCA, CRS purposes
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
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 - Nigeria: No retroactive application of tax law changes unless expressly stated (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
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 - 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
2 Aug - Bolivia: Guidance concerning tax payment facilities
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
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 - 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 - UK: HMRC consultation on collecting data from taxpayers
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 - UK: Draft legislation to implement Pillar Two published
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 - 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
14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council
13 Jul - Germany: Updated CRS guidance
12 Jul - China: Readjusted scope of voluntarily disclosures of customs adjustments
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
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: 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: Amendment to interest on back taxes and tax refunds
28 Jun - Malta: Update on transfer pricing landscape
28 Jun - Philippines: Tax audits, compromise penalties (court decisions)
27 Jun - UK: Background and implications of delayed implementation of Pillar Two
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
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
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 - 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)
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 - 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
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 - 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 - Costa Rica: Guidance regarding suspended deadlines for procedures before tax administration
23 May - Germany: Initiation of FATCA submission reporting period 2021
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
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 - KPMG report: Public consultation meeting on implementation framework of global minimum tax
16 May - Vietnam: Measures to strengthen tax administration for e-commerce activities
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 - India: No permanent establishment under India-Singapore tax treaty (tribunal decision)
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
5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico
5 May - Singapore: Updated guidance on FATCA and CRS return filing
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 - 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
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)
April 2022
29 Apr - Hong Kong: Profits found to be offshore-sourced, not subject to profits tax (court decision)
28 Apr - Spain: Requirements for invoicing computer software and standardized record format
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 - United States: Request for recommendations for IRS 2022-2023 Priority Guidance Plan
25 Apr - United States: Sanctions regarding Russia, FAQs and general licenses
25 Apr - Bolivia: Extended deadline for filing corporate income tax forms, statements
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
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 - Netherlands: “Box 3” (wealth tax) and restoration of rights; future and pending legal proceedings
15 Apr - Luxembourg: Implementation of TIN field instructions for FATCA reporting purposes
15 Apr - Malaysia: Tax corporate governance framework and guidelines
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 - 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 - 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
7 Apr - India: Payments for online advertisements not taxable in India (tribunal decision)
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 - OECD: New inventory of tax technology initiatives
5 Apr - United States: Temporary regulations under section 245A held invalid (federal district court)
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 - 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)
March 2022
31 Mar - United States: Deferred compensation received by nonresident alien individuals (IRS practice unit)
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)
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
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
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 - 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 - UK: VAT incurred in selling shares may be recoverable (tribunal decision)
18 Mar - Portugal: Taxation of dividends received by foreign UCITS contrary to EU law (CJEU judgment)
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 - 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 - 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 - Barbados: Deadline for pre-2021 FATCA and CRS reports extended to 15 April 2022
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
10 Mar - Poland: Limit on tax-deductible debt financing costs (court decision)
9 Mar - Singapore: Updated FATCA technical guidance and FAQs
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: New Russia-related FAQs released
7 Mar - Poland: VAT, tax relief measures related to conflict in Ukraine
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 - United States: Additional sanctions against Russia, addition of entities to EAR entity list
3 Mar - United States: Rehearing en banc denied in subpart F income case (Sixth Circuit)
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
February 2022
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
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: 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 - 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 - 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 - Australia: Proposal for “patent box” regime
16 Feb - British Virgin Islands: Annual fee for FATCA, CRS, and country-by-country reporting portal
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
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 - 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
4 Feb - Channel Islands: FATCA and CRS reporting deadlines extended to 31 March 2022 (Guernsey)
4 Feb - United States: IRS revokes REIT private letter ruling
2 Feb - Nigeria: Transfer pricing outlook for 2022
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
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 - 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 - 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 - 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: 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
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 - 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
16 Dec - Australia: Imported hybrid mismatch rule, final ATO guideline
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 - United States: IRS provides tax relief for taxpayers affected by tornadoes in Kentucky
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
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 - 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 - 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
18 Nov - KPMG report: Transfer pricing and factoring
17 Nov - Chile: “Most favored nation” clause triggered under treaties with Canada and Mexico
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 - 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 - 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 - 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: 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
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
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
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
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: 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 - 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: 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 - Nigeria: Late-filing penalty and interest relief for companies, through 30 November 2021
11 Oct - UAE: User guide for appeals under economic substance regulations
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
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