Global Tax 50 It is tough to look beyond the discussions taking place on how to tax the digitalisation of the economy, but ITR’s Global Tax 50 attempts to do just this. Anjana Haines introduces the ninth edition of the landmark feature that offers a rundown of the most influential individuals, organisations, geopolitical events and trends in the tax world.
Market insight In this month's round-up of changes, we feature the continued expansion of Andersen Global, the establishment of a Nordic powerhouse, and new partners joining firms in London, Netherlands, Lima, across the US and many more.
The unified approach The OECD has embarked upon an ambitious project to redistribute taxing rights around the world in a bid to avoid more unilateral action. Here Pascal Saint-Amans makes the case for the unified approach to pillar one.
The evolution of tax functions will accelerate in 2020 New rules governing international tax in 2020 underscore the importance of the role of in-house tax as a trusted partner embedded across the business, writes Sandy Markwick, head of the Tax Director Network (TDN) at Winmark.
Irish banks lose appeal to resist UK PE capital attribution The UK Upper Tribunal ruled in favour of HMRC in an appeals case, where two Irish financial institutions tried to overturn a past ruling. Murray Clayson explores the case and its implications.
What can companies do to get more certainty outside APAs? Giles Parsons looks at how businesses can reduce uncertainty beyond advance pricing agreements (APAs).
Media furore targets Netflix over corporate tax Despite being compliant with the law, Netflix continues to face harsh criticism for its European tax arrangements. Andrew Parkes, national technical director at Andersen Tax, reviews the company’s trial by media.
The organisations leading change Coupled with the Global Tax 50, Keith Brockman focuses on some of the change-making organisations that have orchestrated significant international tax changes and disrupted age-old tax norms.
Mexico implements BEPS Action 4 to limit interest deductibility The Mexican government has set out to reform the tax system to include the OECD’s recommended limits on interest deductibility in accordance with BEPS Action 4. Mexican tax reform will define 2020.
What Mexican tax reform means for foreign investors The Mexican government, under the leadership of President Andrés Manuel López Obrador (AMLO), approved the first major tax reform of its administration, which will take effect on January 1 2020.
Amazon: GloBE proposal must champion simplicity Amazon has called for simplicity in the OECD’s global anti-base erosion (GloBE) proposal under pillar two of its work on the taxation of the digital economy.
The US supports GloBE, but global taxpayers are hesitant The OECD’s global anti-base erosion (GloBE) proposal under pillar two is broader than taxpayers expected. It risks over-complicating international tax before the impact of the BEPS project settles in.
Netflix calls for the OECD to focus on revenue, not sales In response to the OECD’s unified approach to taxing rights, Netflix has presented its own proposal to tax the digital economy based on revenue instead of sales.
Unilever turns to UN standards for global digital tax proposals Anglo-Dutch corporate group Unilever has called for the OECD to link its digital tax proposals to the UN’s sustainable development goals.
Too many cooks Everyone wants a slice of the tax pie, but if the pie cannot get any bigger does this mean someone will have to go hungry to feed another?
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.
Australia: Tax round-up – Q4 2019 Jock McCormack of DLA Piper summarises the latest topics of interest in Australian tax during the final quarter of 2019.
Chile: Government and Senate’s Finance Commission agree on a range of tax changes Mauricio Valenzuela and Santiago Tubio of PwC outline the main amendments put forward by the executive branch to increase Chilean tax efficiency.
China: China releases DTA guidance to tackle red tape Lewis Lu of KPMG analyses the tax authorities’ fresh guidance on double tax agreements as the push for bureaucratic streamlining continues.
EU: Chances of adopting EU public CbCR directive appears to wane Bob van der Made of PwC looks at the EU's progress on public country-by-country reporting (CbCR) and the deadlock that has emerged.
Germany: Sustaining contract R&D service solutions in a post-BEPS DEMPE context Managing Director Yves Hervé and Associate Director Philip de Homont of NERA Economic Consulting explain how, and under which circumstances, cost-plus solutions for contract R&D arrangements can be sustained in a post-BEPS age.
Greece: Transfer pricing controversy – trends and practical recommendations Christos Kourouniotis of EY discusses the latest trends in the Greek transfer pricing world and outlines his solutions on how to steer clear from potential controversy.
Hong Kong: Hong Kong SAR’s long-standing practice on foreign withholding taxes Lewis Lu and Curtis Ng of KPMG look at changes by Hong Kong SAR’s Inland Revenue Department to its foreign withholding tax treatment that could increase of the cost of doing business for multinational groups
Indonesia: Tax round-up Jeklira Tampubolon and Julius Wahyu Daryono of GNV Consulting Services summarise November’s tax-related developments in Indonesia.
Italy: Tax authorities clarify laws on customer list transfers from a company to a permanent establishment Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse the laws on customer list transfers and explain why this has been a problematic area in Italy.
Malta: Patent box regime launched Rebecca Diacono of Fenech and Fenech Advocates outlines conditions and benefits as Malta introduces new rules to create incentives for qualifying taxpayers.
New Zealand: Inland Revenue updates its multinational enterprises compliance focus Brendan Brown and Matt Woolley of Russell McVeagh assess the impact of Inland Revenue’s latest update to its Multinational Enterprises Compliance Focus document.
Poland: Application for an AEO authorisation through the EU trader portal Agnieszka Kisielewska of MDDP outlines the recent changes that traders face in applying to become an authorised economic operator (AEO) and the benefits that they can reap from the status.
Romania: Transfer pricing controversy on the rise Adrian Rus and Gabriela Bancescu of EY Romania examine the evolving transfer pricing audit environment in Romania.
Russia: Russia’s participation exemption: A clarification A brief update to Nuances embedded in Russia’s participation exemption (ITR, January 29 2019) by Viktoria Ivashchenko, Denis Gamiy and Dmitry Garaev of KPMG.
Spain: A quest to locate risk for insurance premium tax Jorge Moreira Pelaez of Garrigues investigates a potential flaw in how insurance transactions are located, which could lead insurance and reinsurance taxpayers onto difficult territory.
Switzerland: Doing FATCA group requests right Brandi Caruso and Robin King of Deloitte investigate the lessons learned and pitfalls to avoid in responding to FATCA group requests under the Swiss-US double tax treaty.
US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise Distribution Regulations David Forst and James Fuller of Fenwick & West discuss the recent changes which modify the exisiting Section 385 regulations.
US Outbound: OECD’s unified proposal on pillar one poses challenges for dispute resolution Mark Martin and Thomas Bettge of KPMG in the US explore how the OECD’s new proposal on digital era taxation will affect existing dispute resolution tools.
