UK’s Brexit Taxation Bill requires MNEs to pay back CFC state aid MNEs that received tax exemptions from the UK government under controlled foreign corporation (CFC) rules between 2013 and 2018 will be obliged to pay back the tax retrospectively under measures... By Alice Jones December 09 2020
EU Council approves DAC7 digital transparency rules The Council of the European Union approved a legislative proposal to expand the Directive on Administrative Cooperation (DAC) to include information relating to digital platforms. By Alice Jones December 02 2020
MNEs oppose mandatory public CbCR over data inconsistencies Tax directors at multinational enterprises (MNEs) have warned that low data quality and inconsistency in reporting requirements across jurisdictions means public country-by-country reporting (CbCR) should not be made compulsory. By Alice Jones December 02 2020
Efficiency and cost savings crucial to global tax transparency success Tax transparency regimes must be cost efficient and streamlined globally to minimise the burden on both businesses and tax authorities and safeguard taxpayer data, according to tax professionals from corporate,... By Alice Jones November 27 2020
What can we hope for from BEPS 2.0 by mid-2021? Tax directors doubt that there will be an agreement on the OECD’s digital tax proposals in 2021, but want to see a commitment to address unilateral measures, tackle double taxation... By Alice Jones November 24 2020
UN tax convention could overcome EU and OECD blind spots A report by the Tax Justice Network (TJN) argues that EU and OECD efforts on digital tax reforms should be superseded by a UN multilateral tax convention. By Alice Jones November 20 2020
Tax authorities increase APA scrutiny in post-BEPS negotiations Revenue authorities are asking multinational enterprises (MNEs) for more details during advance pricing agreement (APA) negotiations because of the BEPS project, which requires companies to have a more robust APA... By Alice Jones November 18 2020
MNEs grapple with tax implications of overseas employees Multinational enterprises (MNEs) should maintain documentation, track the location of their employees, and allow company directors to delegate responsibility to minimise permanent establishment (PE) and double taxation risks. By Alice Jones November 13 2020
TP litigation risks increase in Latin America as countries follow OECD guidelines Transfer pricing (TP) disputes may increase in Central and South America as tax authorities chase revenue and adopt new tax reporting standards in line with OECD guidelines. By Alice Jones November 12 2020
Tax treaties at risk of political meddling Countries with minimal experience in negotiating tax treaties face obstacles including a lack of solid policy, damaging provisions in existing treaties, and political interference. By Alice Jones November 05 2020
