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There has been substantial debate in relation to the timing of the triggering event for WHT purposes.

Sponsored by PwC Brazil

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.

Bruno Porto, December 09 2020

An imperfect solution but a necessary compromise to avoid a hard border

UK draft law clarifies tax rules on post-Brexit movement of goods

The UK has released draft legislation containing provisions for leaving the EU under a transition agreement on January 1 2021, including the taxation of goods travelling from Great Britain to Northern Ireland.

Alice Jones, December 09 2020

MNEs that accessed the tax exemption may need to pay HMRC up-front, before appeals are settled

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 included in the Brexit Taxation Bill.

Alice Jones, December 09 2020

Corporate tax teams are tapping into the digital opportunities

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.

Anjana Haines, December 09 2020

Understanding the CJEU is key for taxpayers

The Court of Justice of the European Union (CJEU) provides an opportunity to finalise disputes. For tax directors, understanding the special characteristics of the court is essential.

Mattias Cruz Cano, December 09 2020

Poland has adopted a range of changes concerning the taxation of doing business in the country

Sponsored by Russell McVeagh

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Brendan Brown and Tim Stewart of Russell McVeagh summarise Inland Revenue’s draft guidance on negative interest payments and consider how it may impact banks and financial institutions.

Brendan Brown, December 07 2020

MAPs, APAs and other dispute resolution procedures could see an improvement

OECD advances its tax certainty agenda ahead of digital tax reform

Achim Pross, head of the international cooperation and tax administration division at the OECD, says the Forum on Tax Administration’s (FTA) December 8 plenary session may help advance discussions on dispute prevention and resolution tied to the digital tax agenda.

Danish Mehboob, December 07 2020

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