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Tax Dispute Resolution

Tax Dispute Resolution

TaxNewsFlash-Tax Dispute Resolution — KPMG's reports of tax dispute resolution developments from around the globe involving income taxes, transfer pricing, indirect taxes, and other taxes

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Sharon Katz-Pearlman

Head of Global Tax Dispute Resolution & Controversy Services, KPMG International and Partner, KPMG in the US

KPMG International

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TaxNewsFlash-Tax Dispute Resolution

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>> Read the December 2019 edition of Tax Dispute Resolution Quarterly [PDF 2 MB] 

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Recent Articles

February 2020

28 Feb - Netherlands: Data protection, information exchanged with EU countries

28 Feb - United States: Notice of 2020 GSP annual review, deadline for filing petitions

27 Feb - Australia: Updates to CRS reporting instructions

27 Feb - OECD: Draft model rules, reporting for platform operators and sellers in “sharing and gig economy”

27 Feb - South Africa: Transfer pricing measures in budget 2020-2021

27 Feb - Sweden: Foreign investment fund claim for refund of withholding tax (Supreme Administrative Court decision)

27 Feb - United States: Former KPMG tax professional named National Taxpayer Advocate

27 Feb - United States: IRS adds new compliance campaigns on fuel credit, research issues (LB&I division)

27 Feb - United States: No alternative tax credit under section 6426 for butane (federal district court)

26 Feb - Belgium: Final version, circular letter on transfer pricing

25 Feb - Nigeria: Benchmarking related-party transactions, transfer pricing methods (tribunal decision)

25 Feb - Nigeria: Stamp tax collection by tax authority clarified

25 Feb - OECD: Technology to support exchange of tax information

25 Feb - Turkey: Country-by-country reporting, transfer pricing documentation guidance

25 Feb - United States: No “material injury,” fabricated structural steel imports from Canada, China, Mexico

25 Feb - United States: Tax refund dispute when no tax allocation agreement of corporate members (U.S. Supreme Court)

24 Feb - Germany: Arm’s length principle rules, proposed amendments

24 Feb - Russia: Updated CRS guidance

24 Feb - United States: Colorado (multiple audits); Florida (video streaming); New Jersey (combined group NOLs); Ohio (commercial activity tax)

24 Feb - United States: Dismissal of lawsuit against IRS, IRS agents affirmed (Fifth Circuit)

21 Feb - China: Country-by-country reporting update; transfer pricing audit risks

21 Feb - Hong Kong: Possible implications of OECD transfer pricing guidance on financial transactions

21 Feb - UK: Settling double taxation claims, franked investment income and portfolio dividends

21 Feb - United States: FAQs on OFAC reporting, procedure and penalty rules

21 Feb - Australia: More considerations for Australian businesses of OECD transfer pricing guidance for financial transactions

20 Feb - Australia: Implications for Australian businesses, OECD transfer pricing guidance on financial transactions

19 Feb - OECD: Draft reporting rules for platform operators in sharing and gig economy

19 Feb - Spain: Draft legislative proposal for digital services tax

18 Feb - EU: State aid, referrals to CJEU, updates from EU Member States

18 Feb - South Africa: Uncertainty about transfer pricing treatment of financial transactions

18 Feb  - United States: Contractor’s “substantial rights” for research tax credit (U.S. Tax Court)

17 Feb - OECD: “BEPS 2.0” and taxation of digitalised economy, in a nutshell

14 Feb - Austria: Corporate tax group rules not violated by sale of group member (Federal Finance Court)

14 Feb - India: Tax treaty treatment of fees for technical services, of minimum alternative tax

14 Feb - Nigeria: Review of tax cases, tax-related guidance and announcements (2019)

14 Feb - Poland: Tax treatment of “bad debts” and delayed or late payments in commercial transactions

14 Feb - United States: Airline entity agrees to pay $700,000 to settle EAR anti-boycott violations

13 Feb - KPMG report: Insights on OECD’s revised “Unified Approach” to tax challenges of digitalisation

13 Feb - KPMG report: OECD transfer pricing (final) guidance on financial transactions: Initial impressions

13 Feb - OECD: Webcast on tax challenges of digitalisation; Pillar One and Pillar Two proposals

13 Feb - United States: IRS updates and corrects FAQs for QI / WP / WT

12 Feb - Czech Republic: Transfer pricing issues identified in financial statement reviews

12 Feb - Portugal: Car registration tax referred to CJEU

11 Feb - OECD: Transfer pricing guidance on financial transactions

11 Feb - KPMG report: Summary of recent transfer pricing developments, “brave new world”

11 Feb - United States: Federal income tax withholding from employee wages (proposed regulations)

11 Feb - United States: Determining products are made in United States, when ingredients come from other countries" (Federal Circuit case)

10 Feb - Australia: New legislation increases accountability of directors

10 Feb - Japan: Consolidated tax return filing system; shift to Japanese group relief system

10 Feb - Kazakhstan: Tax administrative and procedural changes effective 2020

10 Feb - UK: Arbitration directive-related rules; enhancing cross-border dispute resolution

10 Feb - United States: Interest capitalization for self-constructed assets (IRS practice unit)

10 Feb - United States: Trump Administration budget proposals for FY 2021

7 Feb - Australia: Decision in long-running tariff classification dispute (High Court of Australia)

7 Feb - Belgium: Stock exchange tax on transactions abroad compatible with EU law (CJEU judgment)

7 Feb - Bulgaria: Mandatory disclosure rules, effective 1 July 2020

7 Feb - Italy: Overview of digital services tax

7 Feb - Poland: Mandatory disclosure of cross-border tax arrangements, proposed amendment

7 Feb - UK: Brexit tax implications, EU directives

6 Feb - OECD: Consultation document on review of country-by-country reporting (BEPS Action 13)

6 Feb - Turkey: Tax administration’s draft guidance on digital services tax

5 Feb - Italy: Withholding tax refund, dividends distributed by Italian companies to Spanish pension funds (Supreme Court decision)

5 Feb - Panama: Country-by-country reporting deadline for 2018 extended

4 Feb - Botswana: Overview of transfer pricing rules

4 Feb - Brazil: Possible alignment of transfer pricing rules to OECD Transfer Pricing Guidelines

4 Feb - Luxembourg: New “participating jurisdictions” and “reportable jurisdictions” listed for CRS

4 Feb - United States: Denial of deduction for fines, penalties (regulations pending OIRA review)

3 Feb - EU: Summary of CJEU actions, referrals, EC infringement actions, other tax developments (February 2020)

3 Feb - India: Transfer pricing proposals in Union Budget 2020

January 2020

31 Jan - OECD: Update on digital economy tax issues; “Pillar One” possible safe harbour

31 Jan - UK: Mandatory disclosure reporting of tax planning, final regulations

31 Jan - UK: Revised approach to interest-only assessments on unpaid withholding tax

31 Jan - United States: IRS update on “micro-captive insurance transactions”

30 Jan - Netherlands: Withholding tax on dividends paid to foreign investment funds (CJEU judgment)

29 Jan - Bulgaria: Instructions for collection of information under AEOI

29 Jan - India: GST levied on ocean freight transportation held unconstitutional

29 Jan - Kazakhstan: Tax benefits regime, moratorium on tax audits of small businesses

28 Jan - United States: Overview of the enhanced oil recovery tax credit (IRS practice unit)

27 Jan - United States: “Substitution drawbacks” of wine companies (trade court)

23 Jan - Canada: MAP statistics for 2018

23 Jan - Puerto Rico: Transfer pricing documentation rules, for deduction of intercompany charges

22 Jan - Australia: Guidance addresses non-arm’s length arrangements involving intangible assets

22 Jan - United States: IRS posts “training materials” on the 2017 U.S. tax law

22 Jan - United States: FDAP payments – Statistical sampling and projection procedures (IRS practice unit)

21 Jan - France: Update on digital services tax

21 Jan - Italy: Details of digital services tax

21 Jan - Italy: Tax measures separately accompanying Budget Law for 2020 in “tax decree”

21 Jan - Netherlands: eRecognition mandatory for businesses filing their own tax returns

21 Jan - Taiwan: Customs guidance on one-time transfer pricing adjustment

21 Jan - United States: IRS written supervisory approval required, trust fund recovery penalty under section 6672 (Tax Court opinion)

21 Jan - United States: State high court allows home improvement retailer bad debt deduction concerning sales, B&O tax (Washington State)

20 Jan - Australia: Extension of transition relief, central management and control test

20 Jan - Czech Republic: Income tax treaty with South Korea, entry into force

20 Jan - Czech Republic: Tax administration clarifies VAT amendments

20 Jan - France: Online platforms, XML format for reporting due before 31 January 2020

20 Jan - India: Tax withholding on year-end, GST and composite supplies

20 Jan - Nigeria: Review of tax and regulations for 2019, outlook for 2020

17 Jan - Belgium: Tax developments for financial services sector, potentially in 2020

17 Jan - United States: IRS to consider relief from double taxation related to section 965 repatriation

16 Jan - Nigeria: Finance Act, 2020 introduces digital taxation and service permanent establishment

16 Jan - United States: Written supervisory approval for penalty required before first formal communication to taxpayer (Tax Court opinion)

15 Jan - EU: Summary of CJEU actions, referrals, EC infringement actions, other tax developments (January 2020)

15 Jan - Panama: Guidance for country-by-country reporting, and filing portal

14 Jan - France: Corporate tax provisions enacted in Finance Law for 2020

14 Jan - France: Tax compliance, reporting obligations of online platforms (31 January 2020 action date)

14 Jan - United States: No redemption rights following sales to enforce federal tax liens (Tenth Circuit decision)

10 Jan - UK: VAT treatment of digital newspapers (Upper Tribunal decision)

9 Jan - EU: Transfer pricing developments expected in 2020

9 Jan - Switzerland: Perceived dividend stripping and stock-lending transactions (court decision)

9 Jan - United States: Tax relief for taxpayers affected by January 2020 earthquake in Puerto Rico

8 Jan - India: Taxpayer failure to deposit tax withheld at source

8 Jan - Italy: VAT provisions, digital services tax effective 1 January 2020

8 Jan- United States: UK entity’s income from work on U.S. outer continental shelf held taxable (U.S. Tax Court)

7 Jan - Colombia: New tax law includes measures concerning statute of limitations, tax audit relief, tax settlements, voluntary disclosures

6 Jan - United States: Public hearing concerning France’s digital services tax

6 Jan - United States: Requirement for IRS supervisory approval before penalty assessments (Tax Court opinions)

6 Jan - United States: Sales tax collected for online sales, remitted to state instead of local tax authority (Louisiana)

6 Jan - United States: Sales tax obligations of marketplace facilitators (Michigan, Missouri, Florida)

3 Jan - Belgium: Earnings stripping rules, clarifying decree

2 Jan  - United States: IRS releases annual revenue procedures for 2020

2 Jan - Luxembourg: Mutual agreement procedures (MAP) regime to resolve transfer pricing, international tax disputes

2 Jan - Thailand: Tax calendar for 2020

2019 Articles

December 2019

30 Dec - China: Foreign exchange measures to facilitate cross-border trade and investment

27 Dec - Indonesia: Income tax benefits for new investments

27 Dec - Malaysia: New transfer pricing audit framework (2019)

26 Dec - China: Guidance on annual income tax reconciliation for individual taxpayers

23 Dec - OECD: Guidance for tax administrations, MNE groups on country-by-country reporting

20 Dec - Luxembourg: Legislation passed, repeals advance tax agreements and enacts ATAD 2

20 Dec - United States: FBAR filings, deadline again extended for individuals with signature authority

19 Dec - Italy: Digital services tax, changes made during legislative process

19 Dec - Hungary: Pilot program, standard audit file for tax purposes

19 Dec - Mexico: Tax reform for 2020; focus on international taxation, digital taxation, other items

19 Dec - United States: Proposed regulations on misdirected direct-deposit refunds

18 Dec - Netherlands: Upper House adopts “2020 Tax Plan,” ATAD2, and DAC6

18 Dec - Myanmar: New penalty measures, stamp tax imposed on documents

18 Dec - Nigeria: Tax enforcement program, focused on tax collection

18 Dec - United States: State, local tax changes; KPMG yearly summary for 2019 (table format)

17 Dec - Costa Rica: Transfer pricing reports required from taxpayer group

17 Dec - Sweden: Director’s fees taxed as employment income (high court decision)

17 Dec - Taiwan: Reduced business tax rate, banks’ NCD transactions; refund opportunities

16 Dec - Argentina: Delayed effective date, transfer pricing compliance rules

16 Dec - Poland: Withholding tax rules again delayed, until 30 June 2020

16 Dec - United States: Nebraska (GILTI, FDII); Pennsylvania (sales tax); Texas (gaming machines); Washington State (wooden pallets)

13 Dec - France: High tax court decision on withholding tax base, deduction for professional services; possible refund opportunities

12 Dec - Canada: Year-end preparation, checklist for transfer pricing

12 Dec - Ecuador: New form allows multiple tax payments; electronic invoice requirements

12 Dec - India: Tribunal allows section 10A deduction on additional income resulting from APA

11 Dec - Brazil: Regulation of tax settlements

11 Dec - Costa Rica: Proposal for VAT collection mechanism, cross-border or intangible digital services

11 Dec - Costa Rica: Draft guidelines for processing advance pricing agreements (APAs)

11 Dec - Czech Republic: Bill proposing digital services tax presented to legislature

11 Dec - EU: Amended financial transaction tax proposal

11 Dec - Turkey: Digital services tax enacted, effective date of March 2020

11 Dec - United States: Agricultural cooperative’s computation, allocation of section 199 amounts for patronage and nonpatronage activities

11 Dec - United States: IRS and TTB agree to whistleblower process regarding federal excise taxes

10 Dec - Canada: Alberta facilities to register with CRA regarding fuel charge

10 Dec - India: Sales tax, place where contract for time-charter agreement entered

9 Dec - Mexico: “Certain date” on documents, tax law implications

9 Dec - Nigeria: Basis for computing interest on tax liabilities (tribunal decision)

9 Dec - United States: Relief from broad partner tax basis capital account reporting for 2019

9 Dec - United States: California (franchise tax returns); Chicago (tax rate increases); Iowa (federal tax conformity); South Carolina (taxable delivery charges); Washington State (computing activities)

6 Dec - EU: Energy taxation, EU blacklist discussed at ECOFIN meeting

6 Dec - EU: Summary of CJEU actions, referrals, EC infringement actions, other tax developments (December 2019)

6 Dec - India: Application of MLI to tax treaties with Australia, Finland, Japan, Singapore, Slovakia, UAE

6 Dec - Italy: Financial transaction tax is challenged (CJEU Advocate General opinion)

6 Dec - Sweden: Mandatory reporting requirement rules, effective date July 2020

6 Dec - UK: HMRC online tool, employment status for tax verification

6 Dec -  United States: No change to interest rates on tax underpayments, overpayments (first quarter 2020)

4 Dec - KPMG report: Comments on OECD’s global anti-base erosion (GloBE) proposal under Pillar Two

4 Dec - Netherlands: Reduced transfer tax, office building converted into residential apartments

4 Dec - OECD responds to U.S. Treasury’s letter on digital services tax

4 Dec - United States: Treasury opposition to digital services tax initiatives, support for Pillar One

4 Dec - United States: Disregarded limited partnerships no longer subject to filing requirement or annual tax in California (possible refund opportunities)

3 Dec - Austria: Court addresses abusive assignment of receivables; brief descriptions of other tax developments

3 Dec - Belgium: Tax prepayments and effects of earnings stripping rules

2 Dec - United States: Conclusions, trade-related investigation of France’s digital services tax

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