ITR Global Tax 50 2020-21 The 10th edition of ITR’s Global Tax 50 highlights the most influential figures and events in fiscal policy over the past year, while noting who and what will be particularly important in 2021.
Market insight There have been numerous promotions to partner across law firms in Spain, the US, the UK, Australia, the Netherlands, and Germany.
From intern to global vice chair: Lessons learned from EY’s Kate Barton Kate Barton, EY global vice chair of tax, discusses the trends shaping the tax industry, and what this means for students and graduates starting their career today, having started as an EY intern herself.
US tax reform: A new administration and remedy Keith Brockman reviews what the Biden tax plan will mean in practice.
Indian court confirms Redington’s use of foreign subsidiaries avoided tax Sanjeev Sharma, principal director of income tax at the India Income Tax Department, explains why the Madras High Court decided Redington India’s use of foreign subsidiaries to transfer shares offshore was an attempt to avoid capital gains tax and transfer pricing rules in India.
Taxation of plastics could trigger a litigation wave As the environmental impact of non-recyclable plastic waste becomes an area of tax policy focus, tax professionals foresee that this will become a new area for litigation.
What taxpayers can expect in 2021 COVID-19 shook the global economy in 2020, but the tax world has seen upheaval on multiple fronts. This year will see much more change in terms of OECD-led reform and environmental taxes.
ITR Awards 2021 and World Tax/World TP rankings research now open for submissions Companies, firms and individuals can now enter for the 2021 ITR Americas Tax Awards, ITR Asia-Pacific Tax Awards and ITR Europe, Middle East and Africa Awards.
Ensuring effective AEOI: Global Forum’s peer reviews set direction for 2021/2022 Head of the Global Forum Zayda Manatta, along with Radhanath Housden, head of the AEOI Unit, and Adrian Wardzynski, policy advisor, outline the results of the 100 AEOI peer reviews and the upcoming work to ensure an effective AEOI Standard.
What direct tax teams can learn from indirect tax innovation Direct tax teams are looking at how their indirect tax colleagues have digitalised their processes to apply the same lessons to corporate tax matters, but indirect tax managers warn that technological transitions are not easy.
Countdown to digital tax The OECD held a two-day conference on January 14-15 to allow stakeholders to discuss its blueprints for digital tax reform ahead of the G20/Inclusive Framework meeting later in January.
Financial sector prepares for significant tax changes Hansuke Consulting held its second Financial Services (FS) Tax Conference on November 18-19 2020.
How to prepare for the OECD digital tax reforms Giles Parsons looks at how tax directors can prepare their businesses ahead of the OECD’s digital tax framework being agreed and implemented.
China strengthens litigation framework through increased use of APAs and MAPs Xiaoyue Wang and Choon Beng Teoh of KPMG China explain how recent developments affirm the programmes’ effectiveness in providing certainty to transfer pricing arrangements in China.
How COVID-19 has impacted global M&A activity Deloitte’s practitioners from across the globe assess how transactional activity has evolved as a result of the coronavirus pandemic and consider the key aspects of the new deal landscape.
Biden administration has positive outlook on digital tax negotiations Secretary of the Treasury Janet Yellen will likely restart US negotiations with the OECD and other countries on finalising a multilateral tax approach to the digital economy in the coming weeks.
UK opts out of DAC6 to follow OECD rules after Brexit The UK tax authority, HM Revenue and Customs (HMRC), has removed many EU mandatory disclosure requirements ahead of the January 30 filing deadline, and announced plans to adopt the OECD’s mandatory disclosure rules to replace DAC6.
Facebook’s decision to shift IP to US reflects industry tax concerns Facebook’s decision to dismantle three of its Irish holding companies and repatriate its intellectual property (IP) licences back to the US may be a sign of growing of unease in the technology industry.
Improved clarity on IR35 changes proving useful for UK MNEs Taxpayers have welcomed the certainty gained on IR35 ahead of the April effective date, but tax professionals continue to argue that the employment tax system is fundamentally unfit for purpose and needs reforming.
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: ATO announces guidance on withholding tax concessions and updates APA procedures Jock McCormack of DLA Piper highlights the key tax-related developments from late 2020 in Australia.
Brazil: STJ confirms the triggering event for withholding tax Bruno Porto and Mark Conomy of PwC Brazil discuss the Brazilian Superior Tribunal of Justice's decision confirming the triggering event for income withholding tax over foreign debts.
Chile: IRS issues guidance on requirements for the DDT treaty scenario to apply Mauricio Valenzuela and Santiago Tubio of PwC Chile describe the updated guidance, which includes the use of a flow through entity approach.
China: FDI restrictions continue to be relaxed Lewis Lu of KPMG China explains how the country has introduced a range of business-friendly policies to incentivise foreign investment in 2021.
France: Twin cases reduce the scope of taxing capital gains on sale of French shares Nicolas Duboille and Alexia Dal Ponte of Sumerson analyse recent case law concerning the application of the French capital gain tax applicable to non-resident entities on the transfer of a significant shareholding in a French entity.
Germany: Taxation of the digital economy - Analysing user base value Yves Hervé and Philip de Homont of NERA Economic Consulting present a case study on considering the data-based economic valuation of user contributions.
Greece: ASC rules on the tax treatment of interest-bearing loans concerning stamp duty and VAT Maria Iliopoulou of EY in Greece explains the key conclusions which emerged from the Greek Administrative Supreme Court’s recent decisions on the granting of non-banking loans.
Hong Kong SAR: IRD issues guidance on ship leasing tax concessions Lewis Lu and John Timpany of KPMG analyse the impact of the ship leasing concessions on taxpayers.
India: Tax treaty overrides dividend distribution tax, rules Delhi Tax Tribunal Shashidhar Upinkudru and Vishal Lohia of Dhruva Advisors assess the impact of the Tax Tribunal’s ruling and consider how this may affect the tax position of Indian companies with significant foreign parentage.
Indonesia: Interest rate changes for penalties wrap up a busy 2020 Benjamin Simatupang and Dwipa Abimanyu Dewantara of GNV Consulting discuss national tax developments on the stamp duty law, the treatment of luxury goods, and the import of COVID-19 vaccines.
Italy: The case law on non-interest bearing loans and the arm’s-length principle Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse a recent judicial decision which looks at the tax implications of inter-company transactions in Italy.
Luxembourg: Mapping the EU’s path to sustainable tax governance Grégory Jullien of Deloitte Luxembourg looks at how tax policy is evolving to create a more transparent and sustainable environment for businesses in the EU.
Mexico: Assessing the tax reforms of 2021 Mauricio Martínez D´Meza Violante and Ricardo Gonzales Orta of Deloitte Mexico analyse the key highlights of the Mexican tax reform and assess the shortcomings of the amendments which did not pass.
Netherlands: Recovery of VAT - CJEU rules that actual use takes precedence over intention Daan Arends and Sebastiaan Wijsman of DLA Piper Netherlands explain how a recent judgment by the ECJ broadens the opportunities to recover VAT on costs incurred in the case of unrealised transactions.
New Zealand: IRD considers application of WHT rules to negative interest payments Brendan Brown and Tim Stewart of Russell McVeagh summarise Inland Revenue’s draft guidance on negative interest payments and consider how it may impact banks and financial institutions.
Romania: Considerations on country-by-country reporting requirements Adrian Rus and Gabriela Bancescu of EY Romania take a closer look at the transfer pricing compliance and reporting obligations for businesses operating in Romania.
Poland: Changes for limited partnerships lead 2021 tax developments Monika Marta Dziedzic of MDDP summarises the key elements that businesses and taxpayers in Poland should anticipate following the announcement of a range of tax regulations in November 2020.
Singapore: Non-budget amendments from the Income Tax Amendment Bill 2020 Sivakumar Saravan and Liew Kin Meng of Crowe Singapore consider the key provisions from the amendments including the surcharge for tax avoidance arrangements, and car-related expenses.
25 years of Swiss VAT: The partnership with the Principality of Liechtenstein Tim Reck and Matthias Höhn of Deloitte outline obvious differences and commonalities between the VAT laws of Switzerland and its neighbour Liechtenstein.
Thailand: A closer look at the updates to CbCR Andrew Jackomos and Rohit Sharma of HLB Thailand assess how country-by-country reporting (CbCR) regulations are evolving in Thailand, and consider the implications for businesses.
US: New horizons for dispute resolution under pillar one’s Amount A Mark Martin and Thomas Bettge of KPMG in the US describe the Amount A tax certainty process in the recently released pillar one blueprint and explore how it might work in practice.
