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KPMG’s Week in Tax: 27 – 31 May 2019

KPMG’s Week in Tax: 27 – 31 May 2019

Tax developments or tax-related items reported this week include the following.

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Transfer Pricing

  • Panama: There is a June 2019 deadline for taxpayers required to file a transfer pricing information return on form F930 for transactions with related parties that took place during 2018. Also, for fiscal year (FY) 2018 reporting purposes, there is a new version of F930—one that requires more information from taxpayers.
  • Zimbabwe: The transfer pricing rules in Zimbabwe apply for taxpayers operating in more than one tax jurisdiction and having cross-border transactions with related parties or entities, and for taxpayers that are part of a domestic group of companies and that have intercompany transactions with local (domestic) related parties.
  • Argentina: The requirements and deadline for filing transfer pricing reports and returns has been unified, and in general, the filing deadline is eight months after the fiscal year-end.

Read TaxNewsFlash-Transfer Pricing


FATCA / IGA / CRS

  • Channel Islands: The Guernsey tax authority issued two bulletins with information about the FATCA and common reporting standard (CRS) regimes.
  • India: The tax authority released an updated version of a user guide relating to the FATCA and CRS regimes.
  • Taiwan: The tax authority issued an updated version of “frequently asked questions” (FAQs) as guidance relating to the CRS implementation and due diligence procedures.
  • Belgium: An online portal is open for the submission of CRS returns for the 2018 reportable year..

Read TaxNewsFlash-FATCA / IGA / CRS


Africa

  • Nigeria: Forensic investigatory audits of “deposit money banks” are being planned to verify whether these banks (there are 22 banks subject to the audits) have been adequately charging and collecting stamp tax (duty) on “qualifying transactions” for the periods 2000 to 2018.
  • South Africa: Carbon tax legislative measures has an effective date of 1 June 2019.

Read TaxNewsFlash-Africa


Americas

  • Aruba, Barbados, and Bermuda: All three jurisdictions have been removed from an EU blacklist of non-cooperative tax jurisdictions after agreeing to changes that will address EU concerns about their tax systems.
  • Canada: Tax measures in Saskatchewan’s 2019 budget concern the potash production tax (effective 1 April 2019) and introduce three non-refundable individual (personal) tax credits (effective 1 January 2020).
  • Canada: Legislation in Alberta has been proposed to repeal parts of the province's carbon tax, effective 30 May 2019.
  • Canada: New federal fuel charge reporting requirements begin 31 May 2019 for prescribed producers, distributors, and users in “listed provinces.”
  • Bermuda: Concerning economic substance requirements, organizations conducting certain activities in Bermuda are required to submit data to the Registrar of Companies before a July 2019 effective date.
  • Chile: The tax administration established value added tax (VAT) rules for taxpayers providing services that are exported and used entirely abroad. 

Read TaxNewsFlash-Americas


Asia Pacific

  • New Zealand: Tax measures included in the 2019 budget generally focus on a “business as usual” approach.
  • Australia: The government of Victoria (where Melbourne is located) released draft legislation to impose excise tax (duty) on the acquisition of fixtures located in Victoria, among other measures. This draft legislation followed the release of the budget in Victoria that included business tax relief and a payroll tax reduction.
  • Japan: The Tokyo metropolitan government has proposed changes to the tax rates for Tokyo businesses—expected to be considered in the second ordinary session (from 4 June to 19 June 2019) of the Tokyo metropolitan assembly.

Read TaxNewsFlash-Asia Pacific


Europe

  • Italy: A law enacted in Italy provides rules in the event of a “no deal Brexit” for UK entities conducting business operations in Italy and for Italian entities conducting business in the UK.

Read TaxNewsFlash-Europe


United States

  • Proposed regulations provide guidance under section 3405 with respect to withholding tax requirements on certain periodic and non-periodic distributions.
  • A public hearing will be held on 10 July 2019 with regard to proposed regulations concerning the deduction for “foreign-derived intangible income” (FDII) and “global intangible low-taxed income” (GILTI) under section 250.
  • OMB’s Office of Information and Regulatory Affairs (OIRA) received for review from the U.S. Treasury Department proposed regulations as guidance under section 245A—a new section added by the 2017 tax law to establish a participation exemption system for the taxation of foreign income.
  • A KPMG report provides initial impressions of final regulations designed to coordinate the application of section 956 with the new participation exemption system introduced by the 2017 tax law
  • Rev. Proc. 2019-25 provides the inflation adjusted amounts for health savings accounts (HSAs) for calendar year 2020.
  • Legislation in Alabama would significantly revise the state’s financial institution excise tax, effective for tax years beginning after 31 December 2019.

Read TaxNewsFlash-United States
 

  • A KPMG report provides preliminary observations about a proposal to revise the taxation of carried interests (the bill was introduced by Senator Ron Wyden (D-OR), the ranking member of the Senate Finance Committee).

Read TaxNewsFlash-Legislative Updates


Indirect Tax

  • Canada: Legislation in Alberta would repeal parts of the province's carbon tax, effective 30 May 2019.
  • United States: A bill in Alabama would revise the state’s financial institution excise tax.  
  • Australia: Proposed legislation in Victoria would impose excise tax (duty) on the acquisition of fixtures located in Victoria. The budget in Victoria includes land tax proposals to address the reduction in stamp tax (duty) collection.
  • Chile: Rules have been established for taxpayers providing services that are exported and used entirely abroad and information about related VAT refund requests.
  • Nigeria: Audits of “deposit money banks” are intended to verify compliance with stamp duties on “qualifying transactions” for the periods 2000 to 2018.
  • South Africa: Carbon tax legislation has an effective date of 1 June 2019.
  • Canada: New federal fuel charge reporting requirements begin 31 May 2019 for prescribed producers, distributors, and users with activities in “listed provinces.”

Read TaxNewsFlash-Indirect Tax

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