Tax and the environment: Planting the seeds for a greener recovery Governments face a historic opportunity to make their economies more sustainable post-COVID-19. Mattias Cruz Cano explains how tax will be central to tackling the climate crisis, but there is no easy path to follow.
Market insight There have been some significant new hires across a range of tax firms around the world.
How tax transparency is driving environmental accountability Keith Brockman looks at how tax transparency is creating a new incentive to develop tax strategies that promote sustainable growth.
In-house tax functions can help reduce corporate carbon footprints As more businesses incorporate environmental sustainability into their defined purpose, in-house tax functions can help facilitate reduced carbon emissions provided they have the support of senior management, says Sandy Markwick, head of the Winmark Tax Director Network.
EU proposals to advance its Green Deal to come in summer 2021 Gerassimos Thomas, director-general of European Commission’s taxation and customs union (DG TAXUD) explains the EU’s vision for a more environmentally friendly future and the two flagship priorities in his tax agenda towards a greener EU.
Carbon pricing is necessary for a green recovery In the wake of the COVID-19 crisis, green public spending is not enough for a green recovery. Decarbonisation requires carbon pricing, argue Kurt Van Dender, head of the tax and environment unit, and Jonas Teusch, tax economist, at the OECD.
Tax uncertainty emphasises the need for reform at ITR’s Brazil Tax Forum 2020 Taxpayers at ITR’s inaugural Brazil Tax Forum said that continued uncertainty across all tax areas only further emphasises the need for tax reform, but politics stand in the way.
Opinion: Brazil’s judicial tax procedures must focus on the rule of law Brazilian Federal Judge Renato Becho discusses the improper use of the Usitecno case as an example of how the country’s judicial system is failing to uphold the rule of law without influence
Women in Tax events highlight the key concerns of tax directors Taxpayers at ITR’s virtual Women in Tax forums held in the Americas and Europe say career progression requires the support of good mentors, a corporate sponsorship programme, building a good network and, most of all, taking advantage of every opportunity that comes your way.
Global TP Forum 2020 ITR’s Global Transfer Pricing (TP) Forum gave a platform to business leaders and tax experts to discuss the most pressing issues in TP policy this year.
Digital tax and DST concerns dominate ITR’s Asia Tax Forum 2020 Indirect tax and transfer pricing dominated this year’s ITR Asia Tax Forum as double taxation risks from digital services taxes (DSTs) continue to rise and many prepare for the OECD’s final digital tax proposals due in October.
China’s Hainan free trade port: Introducing an innovative tax regime to attract investment Nicole Zhang, Eric Zhou and Bin Yang of KPMG China take a deeper look at Hainan’s attractive tax programme to entice investors.
A tax on jet fuel will not significantly reduce emissions Aviation body Airlines for Europe (A4E) argues that taxes on airplane fuel would not significantly reduce emissions and other measures would be more effective in addressing emissions reductions from aviation.
Companies struggle to prepare for post-Brexit tax compliance While the coronavirus pandemic continues to weigh heavy on the shoulders of tax directors around the world, the tax implications of Brexit have not been forgotten.
Digital Economy Summit shines spotlight on OECD digital tax plans The OECD’s digital tax plans were the highlight of ITR’s Digital Economy Summit as the digital marketplace expands amid the COVID-19 pandemic and taxpayers speculate on multiple taxation risks ahead of global agreement.
SOLVIT: An effective tool in addressing EU VAT double taxation Evgenia Kokolia, policy officer at the European Commission (EC), explains how the EU’s free alternative dispute settlement mechanism, SOLVIT, can be an effective tool for businesses trying to deal with VAT double taxation disputes.
Tax team principles can support corporate environment goals Giles Parsons explores ideas and principles that tax teams can adopt to promote a sustainable business strategy that aligns with their company’s objectives to become an environmentally-friendly business.
Ten key considerations to prepare for the post-Brexit landscape Businesses now have just two months to prepare for tax changes that take effect at the end of the transition period. Zoe Hawes of Deloitte UK explores some of the key changes from a tax perspective and the steps that tax teams can take to prepare.
Deriving business opportunities from Italy’s COVID-19 measures Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners consider the investment opportunities, which have arisen from the tax relief measures introduced to revive the Italian economy, following the initial outbreak of the coronavirus pandemic.
OECD’s blueprint on global minimum tax is a ‘compliance monster’ The OECD expects to reach an agreement on its two-pillar digital tax blueprints by mid-2021, but many stakeholders still say the approach is too complicated, while alternative tax proposals risk trade wars and multiple taxation for large businesses ahead of a global consensus-based approach.
COVID-19 introduces additional M&A tax risks and benefits M&A deals are vulnerable to tax risks that have emerged because of COVID-19, including those caused by employees working from home. Yet government aid may offer benefits to savvy buyers.
Brazil’s Supreme Court rulings prolong state tax wars Taxpayers in Brazil have said that the Supreme Court has contradicted and confused the rules on tax incentives granted by states, delaying the end of the country’s tax wars.
India’s Vodafone dispute continues to scare off foreign investment Vodafone’s victory in court against the Indian government will not stop controversial, retrospective tax collections on transfers in India, which continue to limit large business investments in the country.
WTO tariff clearance on Boeing could raise EU-US tension The World Trade Organisation (WTO) has awarded the European Union (EU) the right to impose tariffs on US goods in retaliation against subsidies for aerospace multinational Boeing, threatening to escalate transatlantic trade tensions.
Range of options open to MNEs as Russia amends DTAs Multinational enterprises (MNEs) can choose from a range of options to protect their businesses as Russia pursues amendments to its agreements on the avoidance of double taxation (DTAs) with treaty partners.
MNEs must prepare for future real-time reporting in APAC Businesses operating in the Asia-Pacific (APAC) region should future-proof their compliance systems ahead of the adoption of real-time reporting, particularly in a post-COVID context.
Tax Relief Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.
Argentina: Inspecting the informative regime of tax planning strategies Ignacio Rodríguez and Juan Manuel Magadan of PwC Argentina assess the compliance campaign which will see increased monitoring of tax-planning strategies to prevent potential tax evasion.
Brazil: Tax authorities confirm treatment of foreign reimbursements related to partner-administrators or expatriate costs Alvaro Pereira and Mark Conomy of PwC Brazil explain why the RFB’s publication of SC 2006/2020 has confirmed favourable outcomes for certain transactions although the consequences concerning the broader treatment of foreign reimbursements remains controversial.
Chile: Introducing rules to benefit from 4% WHT and structured agreements Germán Campos Kennett and Mónica Aguilar Valderrama of PwC Chile explain the implications of Chile’s withholding tax rate limitations following the modernisation tax bill.
US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attribution William Skinner and Mike Knobler of Fenwick & West evaluate the final regulations, which had sought to address unintended consequences caused by the earlier repeal of Section 958(b)(4)’s limitation on downward attribution of ownership.
US: Thinking through secondary transfer pricing adjustments Mark Martin and Thomas Bettge of KPMG in the US explore the nature and tax consequences of secondary adjustments arising from transfer pricing adjustments initiated by tax authorities or taxpayers.
Australia: A look at the changes to the corporate residency test James Newnham of DLA Piper analyses the Australian government's interpretation of the ‘corporate residency’ test for non-Australian incorporated companies.
China: Tax measures to enhance Beijing as a services hub Lewis Lu of KPMG China looks at the transformational measures which will facilitate the flow of trade and investment in the Chinese capital.
Hong Kong SAR: A look at the US executive order on shipping tax Lewis Lu and John Timpany of KPMG China analyse the impact of the US executive order on shipping taxes for Hong Kong SAR.
India: Vodafone’s tax woes continue to linger Ajay Rotti and Saurabh Shah of Dhruva Advisors discuss why the Indian government’s reluctance to accept the Vodafone ruling could have a detrimental effect for the international investor community.
Indonesia: Reduced tax rates offered to publicly listed companies Benjamin Simatupang and Fabian Abi Cakra of GNV Consulting highlight the key tax-related developments from September and October 2020 in Indonesia.
New Zealand: Court of Appeal considers cross-border financing tax avoidance appeal Tim Stewart and Matt Woolley of Russell McVeagh discuss the key elements of Inland Revenue’s Court of Appeal win in a tax avoidance case against a leading Australasian drinks company.
Singapore: Looking at the tax framework for the variable capital company structure Sivakumar Saravan and Liew Kin Meng of Crowe Singapore analyse the tax implications of the country’s unique, new corporate entity structure.
France: The difficulty of applying anti-avoidance rules to trusts Nicolas Duboille of Sumerson looks at the decision in the Clive-Worms case, which confirms that anti-avoidance rules targeting undistributed profits realised in low-tax jurisdictions are not easily applicable to trusts.
Assessing the transfer pricing treatment of COVID-19 restructuring Niraja Srinivasan, Yves Hervé and Philip de Homont of NERA Economic Consulting take a closer look at the transfer pricing challenges and solutions that have emerged from restructuring expenses during the coronavirus pandemic.
Greece: Tax administration enhances digitalisation John Goulias of EY in Greece explains the key elements of the Independent Authority for Public Revenue’s platform for the transmission of fiscal data.
Italy: The Supreme Court reports on the scope of the EU DRM Directive Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners take a closer look at the Italian Supreme Court’s report on the recently introduced tax dispute resolution mechanisms.
Luxembourg: EU VAT changes postponed until July 2021 Christian Deglas, Michel Lambion and Eric Reolon of Deloitte Luxembourg explain how the EU laws are evolving to modernise VAT for cross-border e-commerce.
Malta: Applications now open for consolidating income tax Ramona Azzopardi, Fiorella San Martin and Arthur Henrique Pasquini of WH Partners evaluate the key benefits of the Consolidated Group (Income Tax) Rules in Malta.
Netherlands: Proposed Dutch conditional exit tax: EU-proof or not? Jian-Cheng Ku and Tim Mulder of DLA Piper consider the practical implications of introducing a conditional exit tax to the dividend tax act in the Netherlands.
Norway: Amendments to R&D incentive scheme includes compliance changes Mette Lundal and Ragnhild Johannessen of Deloitte Norway explain the implications of the key amendments made to the Norwegian tax credit scheme for research and development (R&D) expenses.
Poland: Evaluating the tax consolidation for groups regime Agnieszka Wnuk of MDDP explains the implications of recent developments concerning the consolidation of tax groups regime in Poland.
Romania: The tax consequences of working from anywhere Corina Mîndoiu and Cătălina Butan of EY Romania consider how national lockdowns have created fresh tax considerations for cross-border workers.
Russia: Supreme Court rules on the offset of input VAT Dmitry Garaev and Vera Shchelina of KPMG Russia discuss the key takeaways from the Supreme Court’s decision in the Zvezdochka case.
Switzerland: Presenting a resilient and stable location in the heart of Europe René Zulauf and Manuel Angehrn of Deloitte Switzerland explain why international investors continue to flock to Switzerland amid the challenging economic environment.
