Recent Articles
February 2023
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)
1 Oct - Bermuda: CRS compliance certification form for 2020 due 15 December 2021
1 Oct - Poland: Updated proposals for changes to withholding tax collection rules
September 2021
30 Sep - Hong Kong: Added to EU “grey list” for tax purposes
30 Sep - UAE: Updated FAQs under CRS regime
30 Sep - United States: High court upholds B&O tax surcharge on banks (Washington State)
29 Sep - KPMG report: Managing transfer pricing and customs risks of cross-border transactions
29 Sep - Cyprus: Extension of filing date for income tax returns for 2019, companies and self-employed
29 Sep - Germany: Interest rate of 6% for tax deficiencies, refunds held unconstitutional
29 Sep - Jordan: Instructions for implementing transfer pricing regime include documentation requirements
28 Sep - United States: House Budget Committee’s report on “Build Back Better Act” (the reconciliation bill)
28 Sep - EU: Update on "public" country-by-country reporting
28 Sep - Channel Islands: Amendments to FATCA and CRS regulations (Guernsey)
27 Sep - Switzerland: Arm’s length price and transfer pricing implications of financial guarantees
27 Sep - Germany: Attribution of profits of permanent establishment without personnel (court decision)
27 Sep - United States: Companies agree to settle violations of Ukrainian and Sudanese sanctions
24 Sep - EU: CJEU actions in tax cases; other tax-related actions of EU institutions
22 Sep - United States: Senate approves Assistant Secretary for Tax Policy
22 Sep - British Virgin Islands: FATCA reporting obligations, U.S. TIN information is mandatory
22 Sep - Netherlands: Proposal to address mismatches in non-arm’s length transfer pricing
22 Sep - Saudi Arabia: Merger of tax and customs authorities is completed
21 Sep - Cyprus: Effective date of tour operators’ margin scheme (court decision)
20 Sep - Belgium: Treaty relief with Luxembourg, for cross-border workers
20 Sep - Bermuda: Compliance actions under CRS requirements
20 Sep - Germany: Updated CRS guidance, self-certification
20 Sep - Hong Kong: Taxation of share grants when subject to forfeiture provisions (court decision)
20 Sep - Poland: “Executed tax strategy” reporting requirements, include transfer pricing information
20 Sep - Singapore: Determining when certain machinery is excluded from property tax (court decision)
17 Sep - Czech Republic: Vacation rentals via online marketplace held business activity, not property lease
16 Sep - Belgium: Excess profit ruling system and state aid scheme (CJEU judgment)
16 Sep - Netherlands: Updated FATCA and CRS guidance
16 Sep - Serbia: Key dates for implementing tax administrative measures
16 Sep - United States: Tax proposals for budget reconciliation legislation approved by Ways and Means
15 Sep - EU: Energy taxation directive
15 Sep - Nigeria: Rivers State government asks high court to dismiss order staying VAT enforcement
15 Sep - Spain: Deadline to claim VAT refund for 2020 is 30 September 2021
14 Sep - Indonesia: Ratification of tax treaties with UAE and with Singapore
14 Sep - Namibia: Transfer pricing adjustments when transaction not at arm’s length
13 Sep - United States: Ways and Means releases additional proposals for markup, including tax increases
13 Sep - Nigeria: Court of Appeal orders Nigerian states to maintain status quo on VAT administration
13 Sep - Singapore: New release of transfer pricing guidelines
13 Sep - Taiwan: Customs requirements when making one-time transfer pricing adjustments
13 Sep - UK: HMRC guidance on disclosing coronavirus job retention scheme (CJRS) claims
10 Sep - Kenya: Effect of late filing of VAT returns on input VAT claims (High Court decision)
10 Sep - Nigeria: Authority of states to collect stamp taxes (duties)
10 Sep - United States: IRS Priority Guidance Plan for 2021-2022
9 Sep - United States: Company to pay $189,000 to settle violations of Iranian sanctions
9 Sep - United States: Determination, disposable gloves from Malaysia not produced by forced labor
8 Sep - Thailand: Reduced withholding tax for payments made via e-withholding system extended through 2022
8 Sep - Cayman Islands: Updated FATCA and CRS guidance
8 Sep - Nigeria: VAT legislation introduced (Lagos State)
7 Sep - Nigeria: Rivers State government orders implementation of state VAT law
7 Sep - Ukraine: Draft legislation concerning the digital economy
7 Sep - United States: Draft forms and instructions in W-8 series
3 Sep - Botswana: Threshold for preparing and filing transfer pricing documentation
2 Sep - Cayman Islands: Updated portal user guide
2 Sep - India: Indirect transfer-related provisions; due dates of electronic filing of forms extended
2 Sep - Malaysia: Study of special voluntary disclosure program for indirect tax
1 Sep - United States: Foreign tax credit (business) general principles (IRS practice unit)
1 Sep - Kazakhstan: “Pilot project” on electronic VAT invoicing exemption
1 Sep - Serbia: Rules relating to electronic invoicing (e-invoicing)
1 Sep - Taiwan: Guidance on application of income tax treaties amended
August 2021
31 Aug - EU: CJEU judgment and referrals, infringement procedures, other developments
31 Aug - EU: Transitional preferential rules of origin under pan-Euro-Mediterranean (PEM) Convention
31 Aug - Germany: Interest rate of 6% for back taxes and tax refunds unconstitutional
31 Aug - Germany: New administrative guidelines for transfer pricing
31 Aug - Hong Kong: Updated AEOI self-certification template for “controlling persons”
31 Aug - Ireland: Updated filing guidelines under CRS regime
31 Aug - Taiwan: CRS data for 2020
30 Aug - Nigeria: VAT, other taxes outside jurisdiction of federal government (Federal High Court)
30 Aug - UK: Draft guidance on uncertain tax treatments
30 Aug - UK: Estoppel by convention used by HMRC (Supreme Court decision)
25 Aug - Cayman Islands: CRS compliance form deadline
24 Aug - United States: House passes budget resolution; implications for major tax legislation
23 Aug - United States: IRS opens application period for 2022 Compliance Assurance Process (CAP) program
20 Aug - Germany: Updated CRS guidance
19 Aug - Chile: Guidance regarding tax examinations
17 Aug - Australia: Corporate tax transparency data to be published
17 Aug - India: Tax relief, computation when book profit increase due to APA or secondary adjustments
12 Aug - United States: Senate infrastructure bill would expand cryptocurrency tax reporting
12 Aug - Netherlands: Increased monitoring of import declarations by Dutch Customs
11 Aug - Bahrain: Economic substance information returns due 31 August 2021
11 Aug - Czech Republic: Tax treatment of disposal costs of assets (Supreme Administrative Court decision)
11 Aug - Czech Republic: Transfer pricing issues remain under scrutiny
11 Aug - United States: Senate passes budget resolution; implications for major tax legislation
10 Aug - United States: Senate approves infrastructure bill, including tax provisions
10 Aug - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 16 August
10 Aug - China Customs streamlines penalty provisions
9 Aug - Hong Kong: Guidance addresses tax residence, permanent establishment, cross-border employee issues
9 Aug - Vietnam: Updated FATCA guidance
6 Aug - South Africa: Proposal to address tax avoidance on wealth transfers to certain trusts by individuals
5 Aug - South Africa: Proposed penalty regime, individual taxpayers not filing income tax returns
5 Aug - OECD: Countries bring preferential tax regimes in line with international standards
5 Aug - Panama: FATCA reporting deadline extended to 15 August 2021
4 Aug - United States: Penalty for failure to include reportable transaction information (IRS practice unit)
4 Aug - India: Long-term capital loss on sale of shares by foreign company allowed, not sham transaction
4 Aug - Mauritius: Income tax treaty with Lesotho
3 Aug - Australia: Common loss carryback errors identified
3 Aug - Mexico: Extension of time, outsourcing personnel rules
3 Aug - UK: Tax on overseas dividends, reliefs, interest (Supreme Court decision in FII group litigation)
2 Aug - United States: Senate releases legislative text of bipartisan infrastructure bill
2 Aug - Bulgaria: Income tax treaty with the Netherlands
2 Aug - China: Simplified procedure for unilateral APAs
2 Aug - Japan: Protocol to amend income tax treaty with Switzerland
July 2021
30 Jul - UK: Large businesses required to disclosure uncertain tax treatment in tax returns
30 Jul - Mauritius: Extended deadline for FATCA and CRS reporting
29 Jul - Poland: Transfer pricing measures in proposed tax legislation
28 Jul - United States: IRS scrutiny of hospitals’ net operating losses
28 Jul - United States: Treaty claims and Form W-8BEN-E
28 Jul - Canada: Temporarily suspended limitation periods to resume 1 September 2021 (Quebec)
28 Jul - EU: CJEU judgment and EFTA referral, state aid ruling, other developments
28 Jul - Hungary: Delayed implementation date, tentative VAT returns prepared by tax authority
26 Jul - United States: Indiana (franchise fee litigation); Michigan (advertising materials)
26 Jul - United States: IRS revises system for filing information returns electronically
21 Jul - Costa Rica: Change to taxpayer status for failures to file returns
20 Jul - Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance
19 Jul - Netherlands: Interest deduction denied in acquisition structure (Dutch Supreme Court)
19 Jul - Sri Lanka: Transfer pricing rules, documentation requirements
19 Jul - U.S. and UAE companies agree to settle violations of Iranian sanctions
16 Jul - EU: Infringement proceedings and referrals to CJEU, other developments
15 Jul - Bahrain: Country-by-country reporting and notification obligations
15 Jul - Oman: Clarification of suspension of country-by-country reporting
14 Jul - Netherlands: Formal investigation of tax rulings, transfer pricing issues (EU General Court)
13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021
13 Jul - Panama: List of reportable jurisdictions updated; CRS reporting deadline extended
13 Jul - Romania: Guide for new tax reporting procedure
13 Jul - Russia: Transfer pricing audits, focus on pre-audit analysis
13 Jul - Seychelles: Tax amnesty available through December 2021
10 Jul - G20 Finance Ministers conclude meeting with agreement for global minimum tax, other measures
9 Jul - United States: FDII and computing qualified research expenses (IRS practice units)
8 Jul - United States: Five-year suspension of tariffs, large civil aircraft disputes with EU and UK
8 Jul - Oman: Country-by-country reporting is suspended
6 Jul - Japan: Updated guidance (Q&As) under group relief system
6 Jul - Madagascar: Transfer pricing documentation requirements
2 Jul - United States: Foreign tax redeterminations (IRS practice unit)
2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
2 Jul - United States: Ways and Means, Finance chairs express support for global minimum tax
2 Jul - Finland: Updated FATCA guidance concerning U.S. TINs
1 Jul - EU: European Commission consultations, European Parliament hearings, ECOFIN report (July 2021)
June 2021
30 Jun - Germany: Legislation transposing ATAD measures (exit taxation, CFC rules, hybrid mismatches)
30 Jun - Germany: Provisions amending arm’s length principle, transfer pricing
30 Jun - United States: Allocation methods of personal use of aircraft (IRS practice unit)
29 Jun - United States: IRS memorandum on TE/GE exam activities
29 Jun - Liechtenstein: CRS and FATCA controls for managed legal entities, banks and insurance companies
29 Jun - Singapore: GST implications of common transfer pricing adjustments
29 Jun - South Africa: Transfer pricing adjustments and implications for VAT purposes
28 Jun - Brazil: Second phase of tax reform proposals are outlined
28 Jun - EU: Changes to VAT rules affecting cross-border e-commerce effective 1 July 2021
28 Jun - Germany: Updated FATCA, CRS guidance
28 Jun - Jordan: Transfer pricing regulations are introduced
28 Jun - Ukraine: Income tax and VAT implications of intra-group services
25 Jun - Australia: ATO revises guidance on tax treatment of software royalties
25 Jun - Austria: The right to use software can qualify as VAT-exempt asset management (CJEU judgment)
25 Jun - Azerbaijan: Update on country-by-country reporting
25 Jun - Liechtenstein: Updated FATCA guidance
24 Jun - United States: IRS releases tax collection data for fiscal year 2020
23 Jun - Ireland: Updated guidance on treatment of profit-sharing plans for FATCA, CRS purposes
22 Jun - Germany: Updated CRS guidance
22 Jun - Isle of Man: Economic substance rules extended to partnerships
22 Jun - OECD: Reporting rules for platform operators regarding sellers in “sharing and gig economy”
21 Jun - Finland: Updated CRS technical guidance
21 Jun - Qatar: Deadline for filing Master files and Local files extended to 30 September 2021
18 Jun - Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures
18 Jun - Malaysia: Common transfer pricing issues arising from intra-group services
18 Jun - UK: Tax tribunal decision confirming tax deductibility of deferred revenue expenditure
18 Jun - Channel Islands: Economic substance and partnerships (Guernsey)
18 Jun - United States: IRS practice unit: Concepts of GILTI
16 Jun - United States: Scheduled outage of FATCA systems
15 Jun - EU: Update on status of “public” country-by-country reporting
15 Jun - Finland: Updated FATCA technical guidance
15 Jun - Sweden: Interest-deduction limitation rules contrary to EU law; EC formal notice
15 Jun - United States: Free trade agreement between Australia and UK
14 Jun - United States: Permanent establishment-related considerations, employees working remotely
14 Jun - United States: Treasury releases the American Families Plan tax compliance agenda
11 Jun - China: Instructions for submitting CRS annual reports
11 Jun - Kenya: Country-by-country reporting proposal in budget 2021-2022
11 Jun - Spain: Final rules for digital services tax; first declaration is due July 2021
11 Jun - United States: Partner’s outside basis (IRS practice unit)
10 Jun - United States: IRS adds a new compliance campaign (LB&I division)
10 Jun - United States: Mandatory 60-day postponement of tax deadlines, federally declared disasters
10 Jun - Nigeria: Guidance for filing naira-denominated tax returns electronically
9 Jun - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 31 July 2021
9 Jun - Cayman Islands: Updated FATCA and CRS guidance
9 Jun - Czech Republic: Status of digital services tax legislation
8 Jun - EU: G7 communique on coordinated reforms of international tax system, European perspective
8 Jun - Netherlands: Termination of income tax treaty with Russia
8 Jun - Switzerland: Implications of EU “public” country-by-country reporting for Swiss groups
8 Jun - Thailand: Monthly tax return filing, payment deadlines extended
7 Jun - Cyprus: DAC 6 cross-border arrangements, reporting deadline extended to 30 September 2021
7 Jun - Japan: Requirements for electronic recordkeeping of tax-related books and records
Jun 7 - KPMG report: Analysis and observations about tax measures in G7 communique
7 Jun - Saudi Arabia: Guidelines and standards for e-invoices
4 Jun - Cyprus: Income tax treaty with the Netherlands
3 Jun - India: GST Council recommends reducing compliance burden
3 Jun - Malaysia: Penalty relief for late payment of GST; service tax exemption for joint development area
3 Jun - Qatar: Reminder of deadlines for tax returns for 2020
2 Jun - United States: Taxpayer not a “bank” and thus not allowed to deduct certain losses (Fifth Circuit)
2 Jun - EU: Political agreement on “public” country-by-country reporting requirements
2 Jun - France: Updated FATCA technical guidance
2 Jun - Taiwan: CRS reporting deadline extended to 2 August 2021
1 Jun - Argentina: Proposal to revise corporate income tax rates, pending in Congress
1 Jun - Australia: Evidence relevant for determining arrangements are at arm’s length (High Court decision)
1 Jun - EU: State aid determinations, referrals to CJEU, other developments
1 Jun - Germany: Cross-border company “split-up” (court decision of first impression)
May 2021
31 May - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2022 budget
28 May - United States: Initial impressions of tax proposals in Biden Administration’s budget for FY 2022
28 May - United States: Green Book—Treasury’s explanation of tax proposals in FY 2022 budget
28 May - United States: Biden Administration’s budget proposals for FY 2022
28 May - Bahrain: Economic substance returns, deadline extended to 31 July 2021
28 May - Channel Islands: Economic substance rules for partnerships (Jersey)
28 May - Ireland: Updated filing guidelines for FATCA
28 May - Brazil: Status of possible transfer pricing rules
28 May - Hong Kong: What are possible considerations for BEPS 2.0?
28 May - Taiwan: Amended CRS measures
27 May - India: FATCA and CRS reporting deadlines extended to 30 June 2021
26 May - South Africa: Documentation for interest-free or low-interest loans involving trusts
26 May - Ukraine: Withholding tax rates under tax treaty and “principal purpose test” (court decision)
25 May - United States: FATCA responsible officer certifications due 1 July 2021
25 May - Barbados: AEOI web portal for FATCA and CRS filings, open until 1 June 2021
25 May - Channel Islands: No deadline changes for FATCA and CRS reporting (Guernsey)
25 May - Germany: Updated FATCA guidance
25 May - Malta: Country-by-country reporting, penalties for non-compliance
25 May - Saudi Arabia: Tax and customs authorities merge into single authority
25 May - UK: Supreme Court dismisses HMRC’s appeal; “staleness” and discovery assessments
24 May - Italy: Updated list of reportable, participating jurisdictions for AEOI under CRS regime
24 May - Nigeria: Suspended country-by-country reporting requirements for MNE branches and subsidiaries
24 May - Thailand: Proposed temporary reduction of customs duty surcharge for inadvertent underpayments
24 May - United States: Allocation and apportionment of deductions, individual taxpayers (IRS practice unit)
20 May - United States: Tax reform proposals—BEAT down, SHIELD up
20 May - United States: Treasury’s report on proposed tax compliance measures; addressing the “tax gap”
20 May - Channel Islands: FATCA and CRS updates (Jersey)
20 May - India: Amendments to GST refund rules and procedures
20 May - India: “Faceless” audits and future rules expected for transfer pricing audits
20 May - Kenya: Country-by-country proposals in Finance Bill, 2021
20 May - Luxembourg: Updated CRS FAQs
20 May - Tanzania: Rendering of intra-group services and transfer pricing audits
20 May - Australia: Intangibles arrangements; a deeper look at ATO’s draft practical compliance guideline
19 May - EU: Analysis of proposed business tax framework
19 May - Qatar: FAQs address transfer pricing documentation
18 May - Bahrain: FAQs on country-by-country reporting
18 May - Barbados: AEOI portal for FATCA and CRS reports, open until 31 July 2021
18 May - EU: CJEU, European Commission, European Parliament updates; state aid rulings (May 2021)
18 May - Poland: Transfer pricing documentation, preliminary agreements and tax haven-related transactions
18 May - Serbia: Measures revising tax treatment of independent contractors
18 May - Singapore: CRS guidance concerning qualifying personal investment companies
17 May - Mexico: List of registered foreign providers of digital services
17 May - United States, EU agree to address steel and aluminum trade issues, customs duties
17 May - United States: CBP headquarters ruling; cotton garments produced in part by forced labor in China
14 May - United States: Updated FAQs provide default codes for missing U.S. TINs
13 May - United States: Eighth Circuit reverses district court, finds regulations are valid
13 May - Bulgaria: Transfer pricing documentation; Local file for 2020 required by 30 June 2021
13 May - Canada: Changes to filing procedure for corporate information returns (Ontario)
13 May - Serbia: New electronic invoicing law, VAT implications
13 May - Panama: Default TINs for FATCA reporting
12 May - Luxembourg: Tax rulings provided no selective advantage (EU General Court)
12 May - Luxembourg: Tax rulings granted to companies resulted in tax advantage (EU General Court)
12 May - Singapore: Transfer pricing guide for multinational entity headquarters
12 May - Taiwan: Rules allowing one-time transfer pricing adjustment
12 May - United States: Proposal to require country-by-country reporting of pre-tax profits, taxes paid
11 May - United States: CFCs changing methods of accounting to alternative depreciation system
11 May - KPMG report: Overview of R&D tax incentives, by country (2021)
11 May - EU: New export controls for “dual-use” goods and technologies
11 May - EU: Update on initiatives for public and non-public country-by-country reporting
11 May - KPMG report: Country-by-country reporting; notification requirements per country (updated)
11 May - Nigeria: Tax collection agents reminded to remit taxes collected by deadline
11 May - Saint Kitts and Nevis: Possible extension of CRS reporting deadline
11 May - Serbia: Tax administrative measures effective in 2022
10 May - UAE: Tax-related penalty regime revised
7 May - Bahrain: New electronic filing requirement for economic substance returns
7 May - China: CRS reporting deadline extended to 16 June 2021
6 May - Bermuda: CRS reporting deadline extended to 30 June 2021
6 May - Canada: APA statistics for 2020
6 May - EU: Resolution of European Parliament on taxing digital economy
6 May - Thailand: Extended deadline for corporate income tax return filing, payment
5 May - Liechtenstein: FATCA, CRS reporting deadline extended to 31 July 2021
5 May - Philippines: Updated guidelines for tax treaty relief
5 May - Spain: Transposition of EU directive (DAC 6) completed
5 May - Taiwan: CRS reporting deadline 30 June 2021; new information
4 May - India: Tax treatment of items under income tax treaties with Singapore and the Netherlands
4 May - United States: Company to pay $13 million to settle alleged ITAR export violations
4 May - United States: FATCA IDES testing, scheduled for June 2021
3 May - United States: USTR hearings this week, investigations of digital services taxes
April 2021
30 Apr - United States: IRS automatically extends QI / WP / WT certification and waiver application due dates
30 Apr - Singapore: R&D expenses under cost-sharing agreement (appellate court decision)
30 Apr - EU: Actions by and referrals to CJEU, European Parliament and EU Council
29 Apr - Saudi Arabia: Force of attraction rules in relation to permanent establishments
29 Apr - Vietnam: Default TINs for FATCA reporting
29 Apr - United States: Updated list of jurisdictions not issuing foreign TINs
28 Apr - United States: President Biden announces American Families Plan, individual tax proposals
28 Apr - United States: Treasury proposals for tax administration reforms
27 Apr - United States: House Ways and Means chair introduces economic plan, includes tax provisions
27 Apr - Kenya: Application of commercial building allowance for years before 2010 (High Court decision)
27 Apr - Switzerland: New income tax treaty with Brazil
27 Apr - British Virgin Islands: FATCA, CRS deadlines extended to 30 June 2021
27 Apr - Kenya: No withholding tax on payments to South African entity under income tax treaty
26 Apr - Australia: Additional default TIN under FATCA regime
26 Apr - Poland: “Ready-to-eat meals” subject to reduced VAT rate (CJEU judgment)
23 Apr - Belgium: New XML scheme for filing reports related to mandatory disclosure rules (DAC 6)
23 Apr - Malta: Tax returns for 2020, filed by fiscal units
23 Apr - Costa Rica: Income tax treaty with UAE
22 Apr - Cayman Islands: Updated FATCA and CRS guidance
22 Apr - Gibraltar: Process for determining whether legal entities are residents of Spain
22 Apr - Luxembourg: “Zero-value message” filings under FATCA and CRS regimes
22 Apr - United States: Marijuana dispensary’s claimed expenses properly denied (Ninth Circuit)
22 Apr - EU: Review of deemed supply rules for online marketplaces, effective 1 July 2021
21 Apr - EU: Summary of CJEU referrals and judgments; EC actions, country updates (April 2021)
21 Apr - Kenya: Tax authority temporarily restrained from collecting minimum tax
21 Apr - Malta: FATCA, CRS reporting deadlines extended to 30 June 2021
20 Apr - Bahrain: FATCA and CRS reports for 2020 due 31 May 2021
20 Apr - Canada: Tax measures in 2021 federal budget
20 Apr - Malta: Update on expectations for transfer pricing rules
20 Apr - Poland: VAT penalty of 20% held incompatible with EU law (CJEU judgment)
19 Apr - Finland: Updated FATCA and CRS technical guidance
19 Apr - Germany: Insurance premium tax for seagoing vessels (CJEU judgment)
19 Apr - United States: Company agrees to pay $435,000 for imports of engineering services from Iran
19 Apr - United States: IRS allows temporary relief from handwritten signature requirement for more tax forms
16 Apr - Singapore: CRS returns for 2020 due by 31 May 2021
16 Apr - Singapore: Guidelines for tax treatment of transactions involving digital tokens
15 Apr - Japan: New FAQ added under CRS regime
15 Apr - Luxembourg: VAT exemption, legal services for adults lacking legal capacity (CJEU judgment)
15 Apr - Nigeria: Transfer pricing awareness survey (KPMG report)
15 Apr - Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures
15 Apr - United States: JCT overview of federal tax system (2021)
14 Apr - Argentina: New digital services tax procedures for Buenos Aires
14 Apr - Brazil: Review of digital services tax proposals
14 Apr - United States: Recommendations for IRS 2021-2022 Priority Guidance Plan
14 Apr - United States: Updated charts reflecting provisions in President Biden’s business tax proposals
13 Apr - Pakistan: Implications of MLI on income tax treaties
13 Apr - Netherlands: Acquisition of real estate legal entity subject to real estate transfer tax
12 Apr - Chile: Tax implications of asset transfers in corporate dissolutions
9 Apr - United States: IRS reminder, FBAR filing deadline remains 15 April
9 Apr - Belarus: Review of transfer pricing measures effective in 2021
9 Apr - Cayman Islands: Updated FATCA and CRS guidance
9 Apr - UK: Proposals for new transfer pricing documentation, new annual related-party transaction return
9 Apr - Zambia: Amendments to country-by-country reporting rules
8 Apr - Costa Rica: Advance pricing agreements, implementing guidance
8 Apr - Italy: Relief measures suspend tax collection, extend digital services tax deadlines
8 Apr - Poland: Rate of property tax, real estate not used in business activity (tribunal decision)
7 Apr - Malta: Updated FATCA, CRS guidance regarding AEOI
7 Apr - OECD: Report on status of international tax agenda, developments
7 Apr - Singapore: Updated FATCA guidance and FAQs
7 Apr - United States: Treasury releases report “Made in America Tax Plan”
6 Apr - United States: Foreign tax credit carryback and carryover (IRS practice unit)
6 Apr - Oman: Guidance concerning administrative tax disputes and VAT zero-rating for medicines
5 Apr - EU: Summary of CJEU judgments, referrals (April 2021)
5 Apr - Finland: Updated FATCA and CRS technical guidance
5 Apr - Liechtenstein: Updated AEOI guidance
5 Apr - United States: IRS TE/GE division announces new compliance initiatives
2 Apr - Nigeria: Automated tax system deployed
2 Apr - Russia: Tax audits of individuals with foreign-held assets, accounts
2 Apr - Netherlands: Tax developments concerning financial institutions (April 2021)
1 Apr - Netherlands: Proposed changes to legal forms, possible tax implications
1 Apr - Australia: Synthesised text of income tax treaty with Indonesia
1 Apr - Channel Islands: Updated FATCA guidance, invalid or missing U.S. TINs (Jersey)
March 2021
31 Mar - OECD: First exchanges of “no or only nominal tax jurisdictions”
31 Mar - Mauritius: Country-by-country reporting deadline, extension to 20 April 2021
30 Mar - United States: APMA program, APA statistics for 2020
30 Mar - Hungary: VAT base reduced by bad debts; five-year limitations period (CJEU judgment)
30 Mar - Italy: VAT online registration portal, reporting cross-border sales and transactions
29 Mar - Australia: R&D tax incentive (Full Federal Court)
29 Mar - India: Tax treaty benefits not available to Dutch fiscally transparent entity
29 Mar - Kuwait: “No objection letters” regarding tax compliance of foreign lenders
29 Mar - Saudi Arabia: Consultation on e-invoicing proposal
29 Mar - UK: Proposed changes to hybrid mismatch rules
29 Mar - UK: Second consultation regarding uncertain tax treatments by large businesses
29 Mar - United States: Additional tax deadlines extended to 17 May
29 Mar - United States: Clothing designs and patterns not eligible research expenses (U.S. Tax Court)
29 Mar - United States: Receipt of dividends or interest from a related CFC (IRS practice unit)
26 Mar – United States: Next steps in digital services tax investigations
26 Mar - United States: Italian company to pay $950,000 to settle violations of Iranian sanctions
26 Mar - France: Treatment of pharmaceutical company’s rebates for VAT purposes; refund opportunities
26 Mar - Serbia: Update on income tax treaties
26 Mar - Switzerland: Guidance on implementing FATCA agreement with United States
26 Mar - UK: “Tax Day” overview of consultations and reviews primarily focused on tax system modernisation
26 Mar - UK: “Tax Day” re-design of tax administration
26 Mar - UK: Updated country-by-country reporting schema
25 Mar - UK: Consultation on transfer pricing documentation requirements
24 Mar - Belgium: Overview of tax and transfer pricing audits of multinational entities
24 Mar - Russia: Updated CRS regulations
24 Mar - Spain: VAT treatment of intra-group services; possible implications of CJEU judgment
23 Mar - United States: Overview of section 965 “transition tax" (IRS practice unit)
22 Mar - Serbia: Arm’s length interest rates for 2021
22 Mar - Sweden: Interest deduction limitation rules, taxpayer’s claim allowed (Supreme Administrative Court)
22 Mar - Canada: Mandatory disclosure of information about certain transactions (Quebec)
22 Mar - China: Proposal for simplified process for unilateral APAs
22 Mar - EU: Summary of CJEU judgments, EC actions (March 2021)
22 Mar - Singapore: Tax treatment of termination payments made under separation agreement (High Court)
19 Mar - Nigeria: Preparation and filing of first CRS return for 2020
19 Mar - Poland: EU VAT Directive precludes Polish measures on period for deducting input tax (CJEU judgment)
18 Mar - Mongolia: First transfer pricing tax assessment
17 Mar - United States: IRS to extend tax filing deadline to May 17
17 Mar - United States: Updated FAQs under FATCA regime; penalty relief for withholding agents
17 Mar - Canada: CRA report on MAP program and statistics for 2019
16 Mar - Hungary: Tax on advertisement upheld (CJEU judgment)
16 Mar - Luxembourg: Guidance on mutual agreement procedures
16 Mar - Poland: Tax on retail sector upheld (CJEU judgment)
16 Mar - Liechtenstein: Updated guidance on AEOI data transmissions
16 Mar - United States: Sale of a partnership interest (IRS practice unit)
15 Mar - United States: Company to pay $216,000 to settle violations of Iranian sanctions
15 Mar - United States: IRS addresses electronic filing of Form 990-T
15 Mar - Cayman Islands: Updated FATCA and CRS guidance
15 Mar - Mexico: Registration reminder for foreign providers of digital services
15 Mar - Netherlands: Third amendment, bill on dividend withholding tax in cross-border reorganizations
11 Mar - Netherlands: Update about tax treaty negotiations with Russia
11 Mar - South Africa: Third-party data annual submissions for AEOI
11 Mar - South Africa: Transfer pricing implications of catch-up payments and retroactive adjustments
10 Mar - Italy: Extended deadlines for digital services tax
10 Mar - OECD: Toolkit on tax treaty negotiations, for use by developing countries
9 Mar - Australia: FATCA reporting deadline extended; U.S. TIN information mandatory for 2020 reporting year
9 Mar - Austria: Technical guidance on changes to CRS XML schema
8 Mar - Netherlands: Mismatches in non-arm’s length transfer pricing, consultation on proposal
8 Mar - EU: Negotiations with United States concluded to adjust agricultural quotas
5 Mar - Channel Islands: FATCA guidance related to missing U.S. TINs (Jersey)
5 Mar - Channel Islands: FATCA and CRS reporting guidance, compliance statement assurance (Guernsey)
5 Mar - United States: European Union and United States to suspend tariffs, large civil aircraft disputes
4 Mar - Taiwan: Updated user guide, CRS portal
3 Mar - OECD: Technical changes in CRS XML schema 2.0
3 Mar - United States: IRS memo for TE/GE examiners; interim guidance on “section 506 notifications”
2 Mar - United States: Interest rates, tax underpayments and overpayments (second quarter 2021)
2 Mar - United States: Updated FAQs for QI / WP / WT
1 Mar - EU: Update on “public” country-by-country reporting proposal, following discussion by ministers
1 Mar - Germany: VAT on cross-border provisions of company vehicles to employees (CJEU judgment)
February 2021
26 Feb - France: Updated FATCA technical guidance
26 Feb - OECD: United States drops “safe harbor” request on proposed digital tax rules
25 Feb - Liechtenstein: Updated FATCA technical guidance for missing TIN
25 Feb - Panama: Guidance for issuing electronic tax receipts and invoices
25 Feb - United States: CRS report on U.S. measures to address Huawei-related issues
25 Feb - United States: Section 263A computation for producers
24 Feb - United States: Credit card “reward dollars” held taxable income (U.S. Tax Court)
23 Feb - Switzerland: Court decision restricts application of U.S. tax treaty on basis of citizenship
23 Feb - Germany: Updated CRS guidance
23 Feb - Malaysia: Update, taxation of digital services by foreign service providers
22 Feb - Argentina: Tax benefits under regime to promote digital “knowledge” economy
22 Feb - Colombia: Tax calendar for 2021
22 Feb - EU: Status of proposal for public country-by-country reporting
22 Feb - EU: Updated “blacklist” of non-cooperative jurisdictions (Dominica added); revisions to “grey list”
22 Feb - Japan: Extended due date for individual income tax returns, payments
22 Feb - Switzerland: Updated CRS technical guidance
19 Feb - France: Updated CRS technical guidance
18 Feb - United States: Company to pay $507,000 to settle violations of multiple sanctions programs
17 Feb - Argentina: Exchanges of country-by-country reports, agreement with United States
17 Feb - Korea: Transfer pricing-related amendments in tax legislation
17 Feb - Liechtenstein: Updated CRS technical guidance
17 Feb - South Africa: Transfer pricing adjustment upheld; no transfer pricing documentation
16 Feb - North Macedonia: Disclosure requirements, ultimate beneficial owners
16 Feb - Australia: Objections on hold as tax authority appeals JobKeeper case
16 Feb - Dominican Republic: Tax amnesty, 90-day extension for applications by taxpayers
15 Feb - Costa Rica: Relief from certain information reporting on form D151
15 Feb - Germany: Updated CRS guidance for financial institutions
15 Feb - UK: Definition of “structure” for capital allowances purposes (Court of Appeal decision)
15 Feb - United States: Interest capitalization for self-constructed assets (IRS practice unit)
12 Feb - Mauritius: Protocol amending tax treaty with Eswatini (Swaziland)
12 Feb - Australia: ATO focus on cross-border financing arrangements
11 Feb - Canada: APA cost-recovery charges cancelled
11 Feb - Germany: Proposed revisions to transfer pricing rules
11 Feb - Malta: Updated FATCA, CRS guidelines on AEOI
11 Feb - United States: Research tax credit disallowed (U.S. Tax Court)
10 Feb - United States: Last in-first out (LIFO) records (IRS practice unit)
10 Feb - Rwanda: Transfer pricing rules
9 Feb - Czech Republic: Evidence establishing a foreign entity’s permanent establishment (court decision)
9 Feb - Serbia: Income tax treaties, as of 1 January 2021
8 Feb - United States: IRS TE/GE division releases summary of “FY 2020 accomplishments”
5 Feb - United States: Trade court finds tariffs on steel imports did not violate Section 232
5 Feb - Cambodia: System for e-filing income tax returns; tax relief
5 Feb - Singapore: CRS registration deadline is 31 March 2021
4 Feb - Australia: ATO guidance, presence of employees not creating permanent establishment
4 Feb - Croatia: Arm’s length interest rate on loans between related parties for 2021
4 Feb - Hong Kong: Updated FAQs concerning AEOI and CRS regime
4 Feb - Norway: New VAT return, electronic filing expected in 2022
Tax Dispute Resolution Quarterly
The Summer 2021 edition of Tax Dispute Resolution Quarterly features articles on:
- Remarkably unremarkable APA results
- U.S. tax reform: BEAT down, SHIELD up
- MAP, more MAP, and ICAP
- Misalignment of CbC reporting and value
- Transfer pricing takeaways from Coca-Cola case
- Survey of global secondary adjustment rules.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.