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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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Tax Dispute Resolution Quarterly

December 2019

The December 2019 edition features articles on CAP updates, purchaser considerations post-Wayfair, advance pricing arrangement for Europe, CFC rules under ATAD, and more.

>> Read Tax Dispute Resolution Quarterly [PDF 2 MB] (December 2019)

Recent Articles

December 2019

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

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

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

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

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

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

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 - U.S. conclusions, trade-related investigation of France’s digital services tax

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