Sovereign Wealth & Pension Funds

Transfer Pricing and BEPS

26 Dec - China: Advance pricing arrangement annual report for 2022

22 Dec - EU: EC publishes FAQs on interpretation and transposition of EU global minimum tax

20 Dec - KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis

20 Dec - EU: Pillar Two global minimum tax implementation summary

18 Dec - OECD: Further administrative guidance on Pillar Two rules; statement on timeline of Pillar One multilateral convention

15 Dec - KPMG report: Transfer pricing implications of Pillar Two minimum tax rules

5 Dec - KPMG report: OECD official provides update on expected transfer pricing guidance
 

United States

29 Dec - Announcement 2024-5: Termination of United States-Hungary tax treaty effective 1 January 2024

19 Dec - Tax treaty update: Income tax treaty with Chile enters into force
 

Americas

27 Dec - Bermuda: Legislation introducing corporate income tax signed into law

21 Dec - Chile: U.S. income tax treaty enters into force
 

Asia Pacific

14 Dec - Australia: Tax announcements in government's 2023-2024 mid-year economic and fiscal outlook statement

6 Dec - Australia: Amendments to new interest limitation / thin capitalisation rules bill referred to Senate committee

1 Dec - Hong Kong: Draft legislation on expansion of FSIE regime to asset disposal gains passed by Legislative Council

Europe

22 Dec - EU: 2023 year-end overview of direct tax initiatives

20 Dec - EU: European Parliament resolution on further reform of corporate tax rules, including BEFIT proposal

20 Dec - Luxembourg: Overview of certain tax developments for 2024

14 Dec - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU judgment)

8 Dec - EU: ECOFIN report addressing “Unshell” and FASTER directives

8 Dec - EU: European Parliament subcommittee on tax matters discussion with code of conduct group on business taxation

Transfer Pricing and BEPS

27 Nov - KPMG report: Transfer pricing of financial transactions

24 Nov - KPMG report: Transfer pricing takeaways from 2022 MAP statistics

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

21 Nov - KPMG report: Pillar Two implications for “U.S. sandwich structures”

14 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2022

9 Nov - EU: Member states approve statements of EU Council and European Commission reconfirming support for Pillar One and Pillar Two
 

United States

30 Nov - House Ways and Means approves Taiwan double-tax relief bill

29 Nov - KPMG report: YA Global v. Commissioner Tax Court decision released

24 Nov - Proposed regulations: Amendments to apply entity approach to partnership loss disallowance rules under sections 267 and 707

21 Nov - KPMG report: IRS hearing on digital asset proposed regulations

17 Nov - KPMG report: IRS rules on treatment of foreign insurance segregated funds for Article XXI Treaty and FIRPTA exemption purposes

17 Nov - KPMG report: New guidance on section 892 entity classification of foreign investment partnerships

16 Nov - Reply brief for petitioners in Moore case

16 Nov - Senate Finance Chairman Wyden releases legislation addressing the treatment of carried interests

16 Nov - KPMG report: U.S. Tax Court decision upholding IRS determination that fund engaged in U.S. trade or business

15 Nov - U.S. Tax Court: Partnership engaged in U.S. trade or business based on activities of asset manager
 

Asia Pacific

21 Nov - Australia: Legislation proposing tax enforcement enhancements

21 Nov - Japan: Overview of tax system (2023)
 

Europe

30 Nov - KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker)

28 Nov - Italy: Legislative decrees implementing tax reform

27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules

Asia Pacific

31 Oct - Australia: KPMG comments on consultation on proposed amendments to new interest limitation / thin capitalisation rules

25 Oct - India: Notification required for taxpayer to claim benefit under income tax treaty most favored nations clause (Supreme Court decision)

18 Oct - Australia: Consultation on proposed amendments to new interest limitation / thin capitalisation rules

16 Oct - Hong Kong: Draft legislation on expansion of FSIE regime to asset disposal gains; updated guidance on FSIE regime

5 Oct - India: Final changes to valuation rules under “Angel Tax”

Europe

31 Oct - Luxembourg: U.S. branch denied permanent establishment status, previous ruling nullified (administrative court decision)

26 Oct - Germany: Draft of updated guidance on reorganization tax law

20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax

18 Oct - France: Tax measures in 2024 draft finance law include Pillar Two implementation and transfer pricing documentation changes

17 Oct - EU: New directive on tax transparency rules for service providers facilitating cryptoasset transactions

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

5 Oct - Ireland: Public consultation on introduction of participation exemption

3 Oct - KPMG report: Comments in response to EC public consultation on proposal to improve withholding procedures (FASTER)

Transfer Pricing and BEPS

27 Oct - KPMG report: U.S. transfer pricing and international tax year-end considerations

17 Oct - KPMG report: Multilateral conventions on Amount A of Pillar One and Pillar Two subject to tax rule, initial observations and analysis

16 Oct - UK: Further analysis of Pillar Two global minimum tax rules in updated Finance Bill 2023 draft legislation

11 Oct - OECD: Multilateral convention to implement Amount A of Pillar One; implementation handbook for Pillar Two global minimum tax

11 Oct - United States: Treasury request for public input on OECD multilateral convention to implement Amount A of Pillar One

5 Oct - France: Draft legislation implementing Pillar Two global minimum tax

3 Oct - OECD: Multilateral convention to facilitate implementation of Pillar Two subject to tax rule

United States

30 Oct - IRS extends acceptance of digital signatures, encrypted emails

23 Oct - U.S. Treasury release: No change to list of countries cooperating with international boycott

19 Oct - Finance Committee files report on Taiwan double-taxation relief bill

16 Oct - KPMG report: IRS announcement of new large partnership audits

16 Oct - KPMG report: Voluntary and mandatory disclosure requirements and options

Asia Pacific

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

25 Sep - Australia: Senate Committee report on new interest limitation and subsidiary information disclosure rules

21 Sep - Australia: Draft legislation to improve tax system

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

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

15 Sep - Australia: New communications protocol for ATO objections

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

Europe

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

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

18 Sep - Ireland: Amendments to patent box regime in response to Pillar Two implementation

18 Sep - Italy: Law directing the government to reform the tax system now effective

18 Sep - Italy: Nonresident company eligible for domestic participation regime for capital gains when selling Italian company (Supreme Court decision)

13 Sep - EU: European Commission proposals for directives on business income taxation framework (BEFIT) and transfer pricing

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

Transfer Pricing and BEPS

29 Sep - UK: Updated Finance Bill 2023 draft legislation, including Pillar Two global minimum tax rules

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

18 Sep - Italy: Draft law implementing Pillar Two global minimum tax

18 Sep - Sweden: Draft law implementing Pillar Two global minimum tax

15 Sep - Netherlands: Memorandum to parliament in response to report regarding bill implementing Pillar Two

5 Sep - UK: HMRC guidance on advance pricing agreements

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

United States

29 Sep - IRS Priority Guidance Plan for 2023-2024

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

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

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

12 Sep - KPMG report: Fall 2023 tax agenda

Americas

25 Aug - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax

18 Aug - Canada: Details of clean economy incentives in draft legislation

15 Aug - Canada: Details of draft revised EIFEL rules

14 Aug - Canada: Draft legislation includes Pillar Two rules and revised DST and EIFEL rules
 

Asia Pacific

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

15 Aug - Singapore: Taxing gains on sale or disposal of foreign assets

10 Aug - Korea: Tax reform proposal for 2023, implications for foreign invested companies

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

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

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

Europe

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

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

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

2 Aug - Germany: Draft tax reform bill
 

Transfer Pricing and BEPS

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

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

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

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

10 Aug - Luxembourg: Draft law implementing Pillar Two global minimum tax

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

3 Aug - KPMG report: Amount B and tax certainty
 

United States

Aug 30 - KPMG report: Proposed regulations expand tax information reporting on digital asset transactions

Aug 14 - KPMG reports: Navigating CAMT

Americas

11 Jul - Canada: New mandatory disclosure rules clarified

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

Asia Pacific

5 Jul - Australia: Legislation proposing changes to interest limitation rules introduced in Parliament

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

Europe

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

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

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

Transfer Pricing and BEPS

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

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

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

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

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

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

19 Jul - KPMG report: Transfer pricing and stock-based compensation

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

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

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

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

12 Jul - OECD: Outcome statement on BEPS 2.0

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

United States

19 Jul - Ways and Means Republicans introduce bill to increase BEAT where countries adopt UTPR

18 Jul - JCT report on U.S. international taxation, ahead of Ways and Means hearing on BEPS 2.0

10 Jul - KPMG report: REITs and the new corporate alternative minimum tax

Americas

27 Jun - OECD: Tax transparency in Latin America 2023

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

Asia Pacific

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

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

22 Jun - Australia: Proposed legislation on new thin capitalisation rules; other tax-related legislation

22 Jun - Australia: Tax authority relies on anti-avoidance rather than transfer pricing arguments in foreign related-party financing dispute (Federal Court decision)

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

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

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

Europe

28 Jun - EU: European Commission guidance on foreign subsidies regulation

28 Jun - Luxembourg: Guidance on reverse hybrid rules

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

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

22 Jun - EU: European Parliament adopts resolution on lessons learned from Pandora Papers

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

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

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

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

6 Jun - Luxembourg: Draft law implementing DAC7

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

Transfer Pricing

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

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

26 Jun - UK: Spring Finance Bill 2023, including Pillar Two global minimum tax rules, substantively enacted

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

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

United States

29 Jun - Final regulations: Additional guidance on transition from interbank offered rates (IBORs) to other reference rates for foreign banks with ECI

22 Jun - Tax treaty update: Senate votes to approve income tax treaty with Chile

5 Jun  - President signs bill to increase debt limit, partially rescind IRS funding

Americas

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

Asia Pacific

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

9 May - Australia: 2023 federal budget released

3 May - Australia: KPMG comments on draft legislation denying deductions for low-taxed related-party intangibles payments

1 May - India: Concessional withholding tax rate for foreign portfolio investors not extended under Finance Bill 2023

Europe

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

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

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

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

15 May - UK: Guidance on interest deduction limitation rule for loans with “unallowable purpose”

4 May - Germany: Guidance on use of OECD commentary in interpreting German income tax treaties

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

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

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

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

Transfer Pricing

30 May - KPMG report: Practical transfer pricing compliance in a complex world

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

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

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

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

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

United States

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

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

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

Americas

28 Apr - Canada: Expanded mandatory reporting obligations

5 Apr - Canada: Preparing for excessive interest and financing expenses limitation (EIFEL) legislation
 

Asia Pacific

28 Apr - Japan: 2023 tax reform proposals enacted

27 Apr - Japan: Proposed reduction in effective tax rate exemption threshold under CFC regime

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

13 Apr - Hong Kong: Consultation document on proposed changes to foreign-sourced income exemption regime
 

Europe

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

27 Apr - Germany: Discussion draft of proposed changes to taxation of partnerships to conform to partnership modernization law

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

20 Apr - Italy: Draft legislation for implementation of DAC7

6 Apr - KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker)

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

Transfer Pricing and BEPS

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

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

3 Apr - UK: Implementation of Pillar Two global minimum tax under Spring Finance Bill 2023

Americas

29 Mar - Canada: Tax provisions in federal budget for 2023
 

Asia Pacific

28 Mar - Hong Kong: Proposal to clarify non-taxation of onshore gains from disposal of equity interests

20 Mar - Australia: Changes to interest limitation rules

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

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

Europe

29 Mar - Germany: Expansion of list of non-cooperative jurisdictions, implications for measures against tax havens

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

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

23 Mar - EU: European Parliament adopts recommendations from report on lessons learned from Pandora Papers

16 Mar - UK: “Spring Budget” 2023

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

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

3 Mar - UK: “Spring Budget” expected 15 March 2023
 

Transfer Pricing and BEPS

27 Mar - KPMG report: Evaluating the equivalence of cost-sharing and cost contribution arrangements

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

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

United States

27 Mar - KPMG report: Stock repurchase excise tax and funding rule considerations for inbound taxpayers

24 Mar - Beneficial ownership information reporting guidance

17 Mar - KPMG report: Crypto crackdown—information reporting in a digital asset world

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

9 Mar - KPMG report: Initial impressions of tax proposals in Biden Administration’s FY 2024 budget

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

Americas

10 Jan - Brazil: Report of tax developments for financial, insurance, real estate sectors

Asia Pacific

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

9 Jan - Korea: Tax reform for 2023

Europe

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: European Commission work program for first half of 2023

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

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

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

25 Jan - Italy: 2023 budget law tax measures, including DAC7 and windfall profits tax on energy

24 Jan - EU countries: Transposition of EU directive, cross-border distributions of collective investment undertakings

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

11 Jan - EU: Update on DAC7 implementation

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

6 Jan - OECD: Further progress on harmful tax practices

Transfer Pricing and BEPS

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

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

24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One

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

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

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

United States

Jan 31 - KPMG report: Proposed regulations providing definition of domestically controlled real estate investment trust, initial analysis and observations

Jan 31 - KPMG report: Year-in-review list of U.S. federal tax developments for 2022 (as reported in TaxNewsFlash)

Jan 25 - KPMG report: Third reinstated Superfund tax adds complexity

11 Jan - KPMG report: Final regulations on exception for U.S. real property interests held by foreign pension funds, initial impressions and observations

11 Jan - KPMG report: Section 163(j) considerations on the disposition of partnership property and partnership interests

10 Jan - House passes IRS defunding bill

4 Jan - KPMG report: Initial observations on round 1 of CAMT guidance in Notice 2023-7

Americas

10 Jan - Brazil: Report of tax developments for financial, insurance, real estate sectors

Asia Pacific

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

9 Jan - Korea: Tax reform for 2023

Europe

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: European Commission work program for first half of 2023

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

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

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

25 Jan - Italy: 2023 budget law tax measures, including DAC7 and windfall profits tax on energy

24 Jan - EU countries: Transposition of EU directive, cross-border distributions of collective investment undertakings

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

11 Jan - EU: Update on DAC7 implementation

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

6 Jan - OECD: Further progress on harmful tax practices

Transfer Pricing and BEPS

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

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

24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One

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

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

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

United States

Jan 31 - KPMG report: Proposed regulations providing definition of domestically controlled real estate investment trust, initial analysis and observations

Jan 31 - KPMG report: Year-in-review list of U.S. federal tax developments for 2022 (as reported in TaxNewsFlash)

Jan 25 - KPMG report: Third reinstated Superfund tax adds complexity

11 Jan - KPMG report: Final regulations on exception for U.S. real property interests held by foreign pension funds, initial impressions and observations

11 Jan - KPMG report: Section 163(j) considerations on the disposition of partnership property and partnership interests

10 Jan - House passes IRS defunding bill

4 Jan - KPMG report: Initial observations on round 1 of CAMT guidance in Notice 2023-7