Sovereign Wealth & Pension Funds Sovereign Wealth & Pension Funds Sovereign Wealth & Pension Funds

30 Dec - United States: Analysis and observations on initial guidance on new 1% stock repurchase excise tax

28 Dec - United States: Exception for U.S. real property interests held by foreign pension funds (text of final regulations)

28 Dec - United States: Foreign government income exception and definition of domestically controlled qualified investment entities (text of proposed regulations)

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

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

23 Dec - EU: Summary of tax-related initiatives in 2022

22 Dec - KPMG report: Provisional agreements in EU on emissions trading, carbon border adjustments, and climate funding

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

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

20 Dec - Hong Kong: Draft legislation on foreign-sourced income exemption regime passed

20 Dec - Netherlands: Tax developments concerning financial institutions (December 2022)

20 Dec - UAE: Corporate tax provisions relating to oil and gas sector

19 Dec - Colombia: Tax reform measures include 15% minimum tax, surcharges, digital services tax

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

16 Dec - United States: Recent developments in taxation of financial products

16 Dec - EU: Council adopts EU minimum tax directive

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

13 Dec - United States: Partnership “distributive share only” rule in corporate alternative minimum tax

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

9 Dec - Brazil: Income tax treaty with United Kingdom signed

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

9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis

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

6 Dec - Italy: Proposed PE exemption for investment manager activities

1 Dec - Hong Kong: Developments with respect to foreign-sourced income exemption regime

30 Nov - Africa: Summary of tax developments (November 2022)

30 Nov - EU: Regulation on foreign subsidiaries distorting the internal market approved by EU Council

30 Nov - Germany: Guidance on stock exchange exception under real estate transfer tax

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

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

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

29 Nov - Japan: Overview of tax system (2022)

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

22 Nov - Canada: Revised excessive interest and financing expenses limitation (EIFEL) proposals

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

18 Nov - KPMG report: U.S. congressional elections and tax policy; preliminary observations

17 Nov - UK: Tax proposals in Autumn statement

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

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

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

16 Nov - EU: Public consultation on new common corporate tax system in the EU (BEFIT) extended to 26 January 2023

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

11 Nov - Hong Kong: Proposed amendments to draft legislation on foreign-sourced income exemption regime, administrative guidance

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

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

11 Nov - UK: Tax considerations for cross-border hybrid and remote working

10 Nov - EU: ECOFIN Council agrees on revised Code of Conduct for Business Taxation

10 Nov - United States: Corporate Alternative Minimum Tax considerations and FAQs

4 Nov - Canada: Changes to excessive interest and financing expenses limitation (EIFEL) rules in 2022 fall economic update

4 Nov - Netherlands: Updated policy statement on hybrid mismatches, deduction allowed in cost-plus situations

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

2 Nov - United States: Year-end tax topics for cryptocurrency investors

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

28 Oct - Hong Kong: Draft legislation on foreign-sourced income exemption regime

28 Oct - UK: Update on policy announcements in Chancellor’s “growth plan”; full autumn statement expected 17 November 2022

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

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

25 Oct - Australia: 2022-2023 federal budget released

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

25 Oct - Netherlands: Consultation on implementation of Pillar Two rules

17 Oct - KPMG report: Comments in response to EC public consultation on the SAFE initiative

17 Oct - UK: Proposed changes to additional rate of income tax and corporation tax rate will no longer proceed

14 Oct - Colombia: Tax proposals in draft legislation include 15% minimum tax, surcharges on certain sectors, digital services tax

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

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

13 Oct - KPMG report: Global formulary apportionment

13 Oct - KPMG report: The arm’s length standard after the pillars

13 Oct - Australia: Consultation paper on BEPS 2.0

11 Oct - Hong Kong: Proposed incorporation of MLI into domestic law

10 Oct - OECD: Tax transparency framework for cryptoassets, proposed amendments to CRS

6 Oct - OECD: Report on tax incentives and the global minimum tax

6 Oct - OECD: Progress report on administration and tax certainty aspects of Amount A of Pillar One; public consultation

6 Oct - EU: Report on EU Parliament meeting with European Commissioner; discussion of solidarity contribution on surplus profits in fossil sector, minimum tax directive

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

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

3 Oct - KPMG report: In defense of the arm’s length principle

3 Oct - United States: Tax treatment of cryptocurrency and challenges of cross-border reporting

30 Sep - OECD: Inclusive Framework on BEPS meeting scheduled for 6 - 7 October 2022

30 Sep - UK: Overview and analysis of Chancellor’s “growth plan”

30 Sep - United States: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation

29 Sep - United States: Beneficial ownership information reporting (final regulations)

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

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

23 Sep - UK: Tax relief measures and tax cuts in Chancellor’s “growth plan”

23 Sep -  United States: Tax provisions in the “Inflation Reduction Act of 2022” relevant to the banking industry; potential implications

21 Sep - United States: A primer on wash sale reporting in a volatile market (updated September 2022)

20 Sep - United States: SEC signals support for country-by-country reporting

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

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

9 Sep - EU: Five EU Member States issue joint statement committing to implementing global minimum tax (Pillar Two)

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

8 Sep - Italy: Legislation to accelerate tax dispute resolution and improve tax court efficiency

8 Sep - Italy: Withholding tax on dividends paid to U.S. pension funds; refund opportunities (Supreme Court decisions)

7 Sep - Netherlands: Tax developments concerning financial institutions (September 2022)

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

26 Aug - Hong Kong: Implementation of Pillar Two deferred to 2024 at the earliest

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

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

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

23 Aug - United States: Further extended phase-in provisions under section 871(m) regulations (Notice 2022-37)

19 Aug - KPMG report: Comments on progress report on Amount A of Pillar One

19 Aug - KPMG report: European Commission business tax agenda

18 Aug - Canada: Draft excessive interest and financing expenses limitation (EIFEL) rules

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

16 Aug - United States: President signs budget reconciliation legislation; KPMG’s report on tax law changes

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

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

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

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

10 Aug - Korea: Tax reform proposals for 2022

8 Aug - KPMG report: Tax guide for countries in Middle East and South Asia region

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

3 Aug - Hong Kong: Profits tax implications on sales of commercial buildings

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

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

29 Jul - United States: Initial impressions of energy tax provisions in draft Senate reconciliation bill

28 Jul - KPMG report: Global overview of environmental taxes, incentives and grants (table)

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

25 Jul - UK: Draft legislation for Finance Bill 2023 and several consultation responses published on “L Day”

21 Jul - EU: Tax-related developments from CJEU, EU Council, European Commission, and EU Parliament

20 Jul - UK: Draft legislation to implement Pillar Two published

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: Treaty with Hungary terminated

14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council

14 Jul - Italy: Withholding tax on dividends paid to U.S. collective investment funds; refund opportunities (Supreme Court decision)

11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation

11 Jul - UK: Closer look at consultation on tax immunity for sovereign investors

7 Jul - UK: Consultation on tax treatment of foreign sovereign investors

5 Jul - EU: Tax-related actions of CJEU, EU Council, European Commission, and EU Parliament

1 Jul - KPMG report: Environmental, social, and governance (ESG) and transfer pricing

1 Jul - Australia: Extension of transition period for residency management and control test

30 Jun - Australia: Treatment of U.S. GILTI under hybrid mismatch rules

29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test

28 Jun - Germany: Application of anti-treaty/directive shopping rule to interest on convertible bond (tax court decision)

24 Jun - Hong Kong: Proposed changes to offshore regime for passive income

22 Jun - Germany: Dividend withholding tax refund rules; reimbursing withholding tax on dividends received from portfolio investments (CJEU judgment)

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy

17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting

17 Jun - EU: Latest court decisions, CJEU referral, EC and European Parliament developments

16 Jun - KPMG report: Update on tax control framework requirements

15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One

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 - UK: CFC group finance company partial exemption rules constitute unlawful state aid (EU General Court)

10 Jun - UK: Office of Tax Simplification review of taxation of income from real property

9 Jun - Australia: Planned consultation in July on taxing U.S. and UK resident financial institutions

9 Jun - Brazil: Tax updates concerning financial, insurance, and real estate industries

8 Jun - China: Preferential corporate income tax policies for Hengqin Guangdong-Macao Deep Cooperation Zone

7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country

7 Jun - United States: Mandatory repatriation tax under section 965 is constitutional (Ninth Circuit)

31 May - Germany: Guidance on repayments of contributions by non-EU corporations

31 May - KPMG report: Tax governance frameworks in Singapore and Malaysia, related income tax and GST benefits

25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation

24 May - Singapore: Tax treatment of appropriation of trading stock and conversion of non-trade/capital assets

24 May - EU: CJEU infringement procedure and referral; developments from EC, European Parliament, and OECD

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

23 May - India: Beneficial ownership provisions may not apply to capital gains article of India-Mauritius treaty (tribunal decision)

19 May - France: “Précompte” system of dividends taxation is contrary to EU law (CJEU judgment)

17 May - Australia: Guidance regarding reduced company tax rate

17 May - Luxembourg: FAQ on mandatory disclosure rules (DAC6)

16 May - UK: Consultation on proposed reforms to capital allowances regime

11 May - EU: Developments from CJEU Advocate General, European Parliament, and OECD

11 May - EU: Proposed debt-equity bias reduction allowance

10 May - India: No permanent establishment under India-Singapore tax treaty (tribunal decision)

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

5 May - Canada: Draft hybrid mismatch legislation

3 May - Italy: Withholding tax exemption on cross-border interest payments applied on look-through basis (court decision)

2 May - UAE: Consultation on new federal corporate income tax system

29 Apr - Hong Kong: Profits found to be offshore-sourced, not subject to profits tax (court decision)

28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps

27 Apr - EU: CJEU, General Court, European Parliament, and OECD updates (April 2022)

22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

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

13 Apr - EU: International tax developments, possible domestic and a cross-border implications

12 Apr - KPMG report: OECD’s proposed crypto-asset reporting framework

12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines

6 Apr - KPMG report: Comments in response to EU public consultation on “Unshell” Directive proposal

5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)

4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested

30 Mar - EU: CJEU, European Commission, European Parliament, and OECD updates (March 2022)

30 Mar - United States: International tax proposals in Biden Administration’s budget for FY 2023

28 Mar - United States: Initial impressions of tax proposals in Biden Administration’s budget for FY 2023

28 Mar - United States: FY 2023 budget: “Green Book”—Treasury’s explanation of tax proposals

22 Mar - Australia: Tax treatment of digital assets and transactions; policy framework review

25 Mar - Japan: 2022 tax reform legislation passed

21 Mar - UK: Qualifying asset holding company regime set to launch 1 April 2022

18 Mar - KPMG report: Updated analysis of Pillar Two model rules for 15% global minimum tax following release of commentary

16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive

9 Mar - United States: Reminder about partnership reporting for tax year 2021 (KPMG report)

8 Mar - United States: JCT releases “Bluebook” on tax legislation in 116th Congress

8 Mar - KPMG report: Comments in response to EC public consultation on proposal for minimum tax directive

25 Feb - Germany: Status of income tax treaties

24 Feb - EU: Updates to list of non-cooperative jurisdictions

24 Feb - KPMG report: Guide to taxes on real estate in Central and Eastern Europe

23 Feb - Italy: Luxembourg fund exempt from withholding tax on Italian dividends; refund opportunities (court decision)

22 Feb - KPMG report: Operational transfer pricing health check

16 Feb - Italy: Luxembourg fund exempt from withholding tax on dividends from Italian companies (court decision)

16 Feb - Spain: Financing structure challenged, tax authorities look through Dutch entity to impose withholding tax on U.S. entity

15 Feb - EU: CJEU judgments and referrals, infringement procedures, other developments

11 Feb - Mexico: Identification of ultimate beneficial owners

8 Feb - United States: Year-in-review list of U.S. federal tax developments for 2021 (as reported in TaxNewsFlash)

7 Feb - UAE: Corporate income tax, what to expect

4 Feb - United States: IRS revokes REIT private letter ruling

1 Feb - EU: Summary of tax-related developments, actions from CJEU and European Commission

28 Jan - United States: Regulations addressing tax treatment of U.S. partnerships and S corporations that own stock of CFCs and PFICs (KPMG report)

14 Jan - Netherlands: Guidance on the Good Practices Tax Control Framework

12 Jan - Mauritius: Removal from EU list of “high-risk third countries”

6 Jan - United States: Determining control in public M&A transactions (KPMG report)

23 Dec - India: Tax highlights of 2021

23 Dec - EU: Proposed directive to neutralize misuse of shell entities for tax purposes

22 Dec - EU: Directive to implement Pillar Two is proposed

22 Dec - KPMG report: Initial analysis of Pillar Two model rules for global minimum tax under OECD/G20 Inclusive Framework

21 Dec - EU: Report of tax developments including actions in CJEU, EC, EU Council

20 Dec - Luxembourg: Overview of certain tax developments for 2022

17 Dec - Australia: Tax and the government's mid-year economic and fiscal outlook

16 Dec - Japan: Outline for 2022 tax reform proposals

15 Nov - United States: President signs bipartisan infrastructure bill, tax provisions are enacted

11 Nov - Asia Pacific: Regional perspective on implementation of BEPS 2.0 as it relates to tax incentives

11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting

10 Nov - EU: Developments from European Parliament, OECD and other international institutions

26 Oct - EU: Summary of tax-related developments, actions from CJEU and European Commission

21 Oct - United States: Treasury statement regarding digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

20 Oct - United States: Year-end tax considerations for cryptocurrency investors

13 Oct - Australia: Proposed expansion of tax treaty network

12 Oct - Ireland: Business tax, VAT proposals in budget 2022

11 Oct - EU: CJEU judgments and referrals, infringement procedures, other developments

11 Oct - UK: Update on asset holding company regime

9 Oct - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0

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

29 Sep - Netherlands: Financial structuring of investments in real estate, implications of Dutch law

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

21 Sep - Canada: Possible tax changes after the federal election

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

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

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

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

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

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

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

9 Aug - United States: Second set of corrective amendments to qualified opportunity fund regulations (KPMG report)

6 Aug - Brazil: Corporate tax measures in pending tax reform

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

4 Aug - United States: Penalty for failure to include reportable transaction information

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

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

30 Jul - UK: Proposed changes to REIT rules

30 Jul - UK: Update on proposed asset holding company regime

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

28 Jul - United States: Treaty claims and Form W-8BEN-E (KPMG report)

20 Jul - EU: Proposals to address money laundering

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

14 Jul - EU: Proposals to reduce greenhouse gas emissions, energy tax measures

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

2 Jul - Brazil: Tax reform proposals

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

1 Jul - Canada: Tax measures in 2021 federal budget (Bill C-30) enacted