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

Sharon Katz-Pearlman

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

KPMG International


Also on

TaxNewsFlash-Tax Dispute Resolution

Subscribe to TaxNewsFlash. Questions? Send an email.

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

>> Go to the TaxNewsFlash homepage

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

© 2021 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal