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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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Recent Articles

June 2020

30 Jun - Netherlands: Complaints advisory committee members not subject to VAT (Supreme Court decision)

29 Jun - Italy: Tax dispute resolution mechanisms, new mutual agreement procedures

26 Jun - Cambodia: Online tax registration required of businesses

26 Jun - United States: IRS updated FAQs on deferral of employment tax deposits, payments

26 Jun - United States: More time allowed for Delaware's unclaimed property voluntary disclosure

26 Jun - Belgium: Guidelines on implementing EU directive, disclosure of cross-border arrangements (DAC6)

26 Jun - EU: Deferral of tax reporting deadlines, DAC amendment enters into force

25 Jun - Luxembourg: FATCA and CRS legislation passed

25 Jun - South Africa: Tax authorities to focus on transfer pricing, Supplementary Budget 2020

25 Jun - United States: IRS offers settlement for docketed Tax Court cases involving conservation easement transactions

24 Jun - EU: Council agrees on deferral of certain tax reporting deadlines

24 Jun - India: Payment of guarantee fees not taxable under tax treaty with Netherlands

24 Jun - Netherlands: Updated decree, rules for mutual agreement procedures

23 Jun - Australia: Transfer pricing guidance; ATO response

23 Jun - Netherlands: Transfer pricing issues

23 Jun - Belgium: Legislation introducing loss carryback rules advances

22 Jun - Belgium: Stock exchange tax upheld by Constitutional Court

22 Jun - Liechtenstein: Updated XML schema under CRS regime

22 Jun - Nigeria: Digital activities subject to tax, “significant economic presence” of foreign companies

22 Jun - United States: Supreme Court denies certiorari, appeal from Ninth Circuit upholding cost-sharing regulations as valid

19 Jun - Bulgaria: Extended deadline for FATCA, CRS reporting

19 Jun - Ireland: Extended deadline for FATCA and CRS/DAC2 reporting

19 Jun - Mexico: Updated FAQs under FATCA and CRS regimes

19 Jun - Netherlands: Bill to tax “excessive borrowing” of company’s substantial interest holders

19 Jun - Poland: Proposal for new corporate income tax regime, the “Estonian solution”

19 Jun - Saint Lucia: Updated FATCA and CRS guidance, extended deadlines

19 Jun - South Korea: Amendments to CRS rules

19 Jun - Taiwan: Updated CRS user guides

19 Jun - United States: Treasury Secretary seeks “pause” in OECD Pillar 1 discussions of digital economy

18 Jun - Barbados: Deadlines for 2019 FATCA, CRS returns extended to 31 August

18 Jun - OECD: Statement about ongoing negotiations, taxation of digital economy

18 Jun - Oman: CRS reporting deadline extended to 31 July 2020

18 Jun - United States: Mailbox rule not applicable for then-ineligible private delivery service (Ninth Circuit)

17 Jun - Australia: Updated information for country-by-country reporting 2020

17 Jun - Finland: Updated FATCA and CRS / DAC2 guidance

17 Jun - Singapore: Incorporation of dental practice; legitimate or tax avoidance?

17 Jun - United States reportedly withdrawing from talks with EU on digital services tax

17 Jun - United States: GAO reports on IRS use of Form 990 data in return examination selection

17 Jun - United States: IRS Services and Enforcement employees continue to accept, transmit documents by email

16 Jun - Belgium: CRS reports for 2019, electronic filing

15 Jun - Luxembourg: Synthesized texts of tax treaties, as amended by MLI

15 Jun - United States: Updated FAQs, relief for nonresidents and foreign business employees affected by travel disruptions

12 Jun - Singapore: Amended CRS regulations

12 Jun - United States: Advance pricing agreement (APA) considerations

11 Jun - Australia: New MAP guidelines, arbitration arrangements for resolving international tax disputes

11 Jun - Czech Republic: MLI deposited with OECD

11 Jun - France: Updated FATCA, CRS technical guidance

10 Jun - Canada: APA statistics for 2019

10 Jun - United States: Recommendations for guidance items for 2020-2021 Priority Guidance Plan (Notice 2020-47)

9 Jun - EU: Summary of CJEU judgments, EC investigations (June 2020)

9 Jun - Nigeria: New application process for tax clearance certificates

9 Jun - Poland: Extension of scope of bad-debt relief for VAT purposes (CJEU Advocate General)

9 Jun - Taiwan: Updated XML schema user guide, CRS regime

9 Jun - UAE: FATCA and CRS reporting portal open until 30 June

8 Jun - Nigeria: Dormant companies to regularise outstanding returns by 30 June 2020

8 Jun - Romania: VAT implications after receiving subsequent price discounts (CJEU judgment)

8 Jun - United States: IRS provides FAQs on NOL carrybacks by certain exempt organizations

5 Jun - United States: President signs legislation providing payroll tax deferral for taxpayers with forgiven PPP loans

5 Jun - Kazakhstan: “Horizontal monitoring” of certain taxpayers

5 Jun - Argentina: Transfer pricing compliance rules, reporting deadline deferred to July 2020

5 Jun - EU: Member States compromise on deferring DAC6 deadlines

5 Jun - Isle of Man: FATCA and CRS reporting deadline extended to 30 September

5 Jun - Saudi Arabia: Transfer pricing guidelines (second edition)

4 Jun Belgium: Update on mandatory disclosure of cross-border arrangements (DAC6)

4 Jun OECD: Taxation of offshore indirect transfers, guidance for developing countries

3 Jun - Brazil: Updated FATCA, CRS guidance

3 Jun - Canada: CRA resumes tax audits

3 Jun - Taiwan: Updated CRS data preparation “tools”

3 Jun - United States: Flow-through entities, effects for individual’s foreign tax credit (IRS practice unit)

3 Jun - United States: Temporary relief allowing retirement plan elections, spousal consents to be signed remotely

2 Jun United States: Investigation of digital services taxes

2 Jun - United States: Transfers of real estate to liquidating trusts not bona fide dispositions (U.S. Tax Court)

1 Jun - China: AEOI portal for CRS reports, open 1 August to 30 September 2020

1 Jun - France: FATCA, CRS reporting deadlines extended to 15 October 2020

1 Jun - Germany: FATCA test system database deleted; data may need to be resubmitted

1 Jun - Nigeria: Foreign companies having “significant economic presence” for tax purposes, including those deriving income through digital means

1 Jun - Switzerland: Report on audit mechanism for implementation of AEOI

1 Jun - United States: IRS updates to FATCA registration system

May 2020

29 May - KPMG report: Intangible property transfer pricing in an economic downturn

29 May - Saint Kitts and Nevis: FATCA, CRS reporting deadline extended to 30 November 2020

28 May - Nigeria: Transfer pricing method; appellate tribunal decision in case of first impression

28 May - South Africa: Third-party data annual submissions for AEOI due 31 May 2020

28 May - United States: House passes bill, payroll tax deferral for taxpayers with forgiven PPP loans

28 May - United States: IRS provides FAQs on treatment of NOL carrybacks and AMT by C corporations

28 May - United States: Postponed deadlines for employment taxes, employee benefit plans, IRAs, HSAs, MSAs, other time-sensitive actions

27 May - Anguilla: Extensions of FATCA, CRS reporting deadlines

27 May - Switzerland: Updates to FATCA guidance

27 May - United States: Taxation of the disposition of U.S. real property interests (USRPI) by foreign persons (IRS practice unit)

26 May - Mauritius: Due date for FATCA, CRS returns extended to 30 September

26 May - Nigeria: Large tax office established for non-oil taxpayers

22 May - Channel Islands: Amendment to CRS regulations (Guernsey)

21 May - Germany: Guidance under FATCA regime

21 May - Mexico: VAT on digital services provided by foreign residents without permanent establishment

21 May - South Africa: Proposal to limit interest deductions on cross-border debt

21 May - Taiwan: Updated XML schema user guide, CRS regime

21 May - United States: Section 1603 grants for wind energy firms, development fees not established (Federal Circuit)

20 May - British Virgin Islands: Updated CRS guidance

20 May - Luxembourg: EC “letters of formal notice” to amend tax law on securitization

20 May - United States: Competent authority, changes regarding requests and APA consultations

20 May - United States: Real property tax impermissibly discriminates against railroads (Fourth Circuit)

19 May - Liechtenstein: Updated AEOI guidance

19 May - Portugal: VAT deduction limitation when capital for new investment is set aside (CJEU Advocate General’s opinion)

19 May - United States: References to NAFTA in U.S. income tax treaties, replaced with USMCA (Announcement 2020-6)

19 May - United States: REIT’s retirement facilities not health care facilities, TRS can provide residential services (PLR) 

18 May - Cayman Islands: FAQs on CRS compliance form

18 May - Germany: Updated CRS guidance for financial institutions

18 May - South Africa: Taxation of gains, losses from foreign exchange transactions (appellate court decision)

18 May - United States: California (proposed NOL suspension); Mississippi (tax refunds, statute of limitations)

18 May - United States: HTSUS classification of jewelry boxes (paper or plastic) (U.S. trade court)

18 May - United States: IRS fact sheet, tax credits for paid leave

18 May - United States: Treasury provides PPP loan forgiveness form, instructions

18 May - United States: Transfer pricing adjustments, potential customs tariff opportunities

15 May - Monaco: Revised AEOI guidance

15 May - United States: IRM update, addressing CARES Act provisions concerning net operating losses and minimum tax credits

14 May - Russia: Draft legislative amendments to revise APA measures

13 May - OECD: Consultation on 2020 review of country-by-country reporting

13 May - United States: Funding rule under section 385 (text of final regulations)

13 May - United States: Conservation easement on golf course eligible for charitable deduction (Eleventh Circuit)

13 May - United States: Additional B&O tax imposed on financial institutions violates Commerce Clause (Washington State)

12 May - EU: Summary of tax developments including CJEU judgments, referrals, EC actions (May 2020)

12 May - United States: COVID-19-related legislation unveiled in House, includes tax proposals

12 May - United States: Disallowed deductions and information reporting for fines, penalties

12 May - United States: Expanded relief for health-related cafeteria plans

12 May - United States: Regulations on charitable donation of conservation easement upheld as valid (U.S. Tax Court)

11 May - Nigeria: Guidance on interpreting, implementing tax law changes in Finance Act 2019

11 May - Singapore: Revised FATCA form released

11 May - UAE: Economic substance reporting requirements

11 May - United States: Accounting method changes, foreign earned income exclusion, other topics (IRS practice units)

8 May - EU: Proposals to postpone filing deadlines, including for EU mandatory disclosure rules (DAC6) 

8 May - Malaysia: Substantial activity requirements, Labuan economic zone

8 May - Japan: Updated FAQs on CRS

7 May - Peru: No changes to transfer pricing filing, reporting obligations

7 May - United States: Relief from creating foreign branch separate units under the dual consolidated loss rules

7 May - United States: State and local tax guidance, tax relief (COVID-19) (updated 7 May)

5 May - Australia: Updated U.S. TIN requirements for 2020

5 May - Cayman Islands: CRS reporting deadline extended to 16 November

5 May - Colombia: No changes to transfer pricing reporting deadlines

5 May - KPMG report: Bolster the resilience of the transfer pricing model (COVID-19)

5 May - KPMG report: Transfer pricing implications for intercompany loans (COVID-19)

4 May - Russia: Proposed withholding tax rate changes, income tax treaties to be renegotiated

5 May - Sweden: Transfer pricing and financial transactions

5 May - Taiwan: Updated CRS portal instructions, XML user guide, FAQs

5 May - United States: U.S. taxpayer realized subpart F income on sales of appliances manufactured in Mexico (U.S. Tax Court)

4 May - Saint Vincent and Grenadines: AEOI reporting cycle suspended

4 May - UK: Updated financial accounts for CRS reporting

4 May - United States: Supreme Court grants certiorari in challenge to IRS notice and compliance with Administrative Procedure Act

1 May - United States: IRS adds new compliance campaign on TCJA (LB&I division)

1 May - United States: State and local tax guidance, tax relief (COVID-19) (updated 1 May)

1 May - United States: New FAQs provided by IRS for QIs / WPs / WTs

1 May - United States: JCT summary of current federal tax system (2020)

April 2020

30 Apr - Canada: Updated FATCA and CRS guidance

30 Apr - Germany: VAT group rules referred to CJEU

30 Apr - Italy: Tax treatment of pensions under tax treaty with Portugal (CJEU judgment)

30 Apr - Netherlands: Multilateral instrument (MLI) now part of tax treaties

30 Apr - United States: IRS adds new FAQs on faxing refund claims, NOL carrybacks under CARES Act

30 Apr - United States: No paper versions of Form 1023 applications accepted after April 30 (IRS reminder)

30 Apr - United States: IRS temporary procedures for electronic submission of requests for letter rulings, closing agreements, other advice

30 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 30 April)

29 Apr - United States: FATCA certification submissions extended to 15 December 2020

29 Apr - United States: Installment method, substantiation requirements, and foreign currency translation (IRS practice units)

29 Apr - United States: IRS updates, expands FAQs on employee retention credit

28 Apr - Channel Islands: FATCA and CRS reporting deadlines are 30 June 2020 (Guernsey)

28 Apr - EU and Mexico conclude negotiations for new trade agreement

28 Apr - Russia: Updated guidance, electronic information reporting under CRS

28 Apr - Singapore: FATCA form to be released 6 May 2020

28 Apr - United States: IRS adds to FAQs on postponed tax return filing, paying deadlines

28 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 28 April)

27 Apr - Poland: Interactive transfer pricing form, Local file

27 Apr - Portugal: Postponed deadline for transfer pricing documentation

27 Apr - UAE: Customs duty refund opportunities (Dubai)

24 Apr - Belgium: COVID-19 implications from a transfer pricing perspective

24 Apr - Puerto Rico: Pending legislative proposals, economic and tax relief

24 Apr - United States: FAQs on NOL carrybacks for taxpayers with section 965 inclusions

23 Apr - Australia: Updated AEOI guidance, CRS participating jurisdictions list

23 Apr - British Virgin Islands: FATCA, CRS deadlines extended

23 Apr - Hong Kong: Amendments to AEOI rules concern “controlling persons”

23 Apr - Singapore: Updated FAQs concerning FATCA

23 Apr - South Africa: Third-party data annual submissions for AEOI

23 Apr - Sweden: Transfer pricing treatment of IP in third-party acquisitions

23 Apr - United States: IRS expands FAQs on postponed tax return filing, paying deadlines (COVID-19)

23 Apr - United States: IRS provides FAQs on NOL carrybacks for taxpayers with section 965 inclusions (COVID-19)

23 Apr - United States: JCT description of employee retention credit, payroll deferral provisions in CARES Act (COVID-19)

23 Apr - United States: Treasury releases updated FAQs on Paycheck Protection Program (COVID-19)

23 Apr - United States: FAQs for determining U.S. trade or business or permanent establishment (COVID-19)

23 Apr - United States: Refund claims for underpayment interest denied, not timely filed within special six-month period (Federal Circuit)

23 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated April 23)

22 Apr - Japan: Deadline extension for AEOI reporting (COVID-19)

22 Apr - Turkey: Transfer pricing documentation requirements, implementation update

22 Apr - United States: IRS extends FATCA reporting deadline, Model 1 IGA jurisdictions 

21 Apr - India: FATCA and CRS returns, reporting deadlines extended

21 Apr - Singapore: Updated FATCA guidance

21 Apr - Turkey: Digital services tax, a primer

21 Apr - United States: Relief for nonresidents, cross-border travel restrictions addressed in revenue procedures and FAQs

21 Apr - Zimbabwe: Extended deadline, transfer pricing returns for 2019

20 Apr - Hong Kong: Taxation of digital assets

20 Apr - Liechtenstein: Consultation on AEOI regime changes

20 Apr - United States: Initial impressions of Rev. Rul. 2020-8  and 10-year limitations period, foreign tax credit and NOL carrybacks

17 Apr - United States: 10-year limitations period, foreign tax credit and NOL carrybacks (Rev. Proc. 2020-8)

17 Apr - United States: IRS expands FAQs on faxing refund claims, NOL carrybacks under CARES Act

16 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 16 April)

16 Apr - EU: Summary of EU tax developments including CJEU judgments, referrals, EC actions

16 Apr - Netherlands: Tax treatment of profits of multinationals, report of advisory committee

16 Apr - UAE: “Substance over form” approach for economic substance

15 Apr - Bangladesh: Transfer pricing inquiries of multinational corporations

15 Apr - OECD: Draft reporting rules for platform operators in sharing and gig economy, comments received

15 Apr - UK: HMRC guidance, registration rules for digital services tax

15 Apr - United States: IRS provides FAQs on transfer pricing documentation “best practices”

15 Apr - United States: FATCA default notices guidance, updated FAQs

15 Apr - United States: LB&I activities that are temporarily suspended, continued

15 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 15 April)

14 Apr - South Africa: Tax recovery by SARS on behalf of foreign governments

14 Apr - United States: New COVID-19 relief imports web portal

14 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 14 April)

13 Apr - Oman: New organizational structure for tax authority

13 Apr - Russia: CRS reporting deadline extended to 31 August 2020

13 Apr - UAE: Economic substance notification deadlines

13 Apr - United States: Safe harbors, loan forbearance programs under CARES Act (Rev. Proc. 2020-26)

13 Apr - United States: State and local tax guidance, tax relief (COVID-19) (updated 13 April)

13 Apr - United States: IRS provides Q&As on “quick refunds” process for NOL carrybacks under CARES Act

13 Apr - United States: IRS cautions certain mechanisms for requesting taxpayer records not available

13 Apr - United States: IRS issues FAQs on deferral of employment tax deposits and payments

13 Apr - United States: IRS practice unit: Statute of limitations on assessment of tax

10 Apr - United States: List of countries eligible for section 911(d)(1) waiver for 2019 (Rev. Proc. 2020-14)

10 Apr - United States: IRS re-issues Form 941 to address employee retention credit

9 Apr - Liechtenstein: Updated instructions, FATCA reporting

9 Apr - United States: Relief for taxpayers affected by coronavirus pandemic (Notice 2020-23) 

9 Apr - United States: Guidance on NOL carryback measures from CARES Act (Rev. Proc. 2020-24)

8 Apr - United States: Relief for partnerships, allowing amended returns (Rev. Proc. 2020-23)

8 Apr - United States: IRS statement on corporate tax refunds

7 Apr - Indonesia: Updated regulations on advance pricing agreements

7 Apr - Malta: Updated FATCA, CRS guidelines on AEOI

3 Apr - Hong Kong: Revised guidance, taxation of digital economy and intersection with transfer pricing

3 Apr - Malaysia: Reminders on preparing for transfer pricing audit

3 Apr - South Africa: Reminder of transfer pricing documentation compliance requirements

2 Apr - Poland: LLC transformation into limited partnership not tax advantaged arrangement

1 Apr - Argentina: Transfer pricing compliance rules, effective date once again delayed

March 2020

31 Mar - Nigeria: Transfer pricing e-filing portal

31 Mar - South Africa: Determining “gross sales” for mineral royalty purposes (Supreme Court of Appeal)

30 May - OECD: Status report, automatic exchange of information (AEOI)

27 Mar - United States: IRS suspends certain administrative procedures (COVID-19)

26 Mar - Canada: Derivative instruments, new clarity for characterization of gains, losses (Supreme Court decision)

25 Mar - Nigeria: Excess dividend tax applies to income exempt from tax (appellate tribunal decision)

25 Mar - United States: New FAQs from IRS concerning QI / WP / WT 

24 Mar - India: Digital taxation, enlarging the scope of “equalisation levy”

24 Mar - Mexico: Non-deduction of payments to related parties in low-tax jurisdictions, interest deduction limitations

24 Mar - Germany: Update on mandatory reporting, cross-border tax planning arrangements (DAC 6)

24 Mar - Luxembourg: DAC 6 transposition, Protocol with France

24 Mar - United States: Considerations for modifying or unwinding related-party transactions, responding to coronavirus (COVID-19)

23 Mar - Italy: Tax procedure-related bank guarantees are refundable (Supreme Court decision)

23 Mar - Nigeria: VAT filing, collection is automated, effective 1 April 2020

23 Mar - United States: 2020 FBAR update; revisit the rules while relief is available

21 Mar - UK: Digital services tax, effective date set for 1 April 2020

21 Mar - UK: Research and development expenditure credit to increase to 13%

20 Mar - Turkey: Digital services tax, update

19 Mar - United States: Centralized risking of cases with research issues (LB&I directive)

17 Mar - France: Deferral of direct tax payments for companies, coronavirus (COVID-19) response

17 Mar - Italy: Suspension of tax audits, response to coronavirus (COVID-19)

17 Mar - Netherlands: VAT treatment of composite services, fund management (CJEU Advocate General opinion in UK referral)

17 Mar - Zimbabwe: Transfer pricing return for 2019 tax year

16 Mar - Denmark: Transfer pricing documentation deadline, reminder

16 Mar - Spain: Digital services tax legislation, update

16 Mar - South Africa: Third-party data submissions for AEOI

13 Mar - Singapore: New income tax treaty with Indonesia

13 Mar - United States: IRS nonacquiescence in payroll tax refund, professional employment organizations (AOD 2020-1)

12 Mar - Italy: VAT on staff secondment, incompatible with EU VAT directive (CJEU judgment)

12 Mar - Mexico: Forgiveness of tax liabilities; question whether penalties or surcharges are covered

12 Mar - Serbia: Related-party interest rates for 2020, transfer pricing documentation implications

11 Mar - Australia: “Sufficiently influenced” is not control, but influence (High Court decision)

11 Mar - UK: Digital services tax proposal in budget; rate of 2% to be introduced from April 2020

11 Mar - United States: Computing alternative minimum tax, foreign tax credit (individual taxpayers)

11 Mar - United States: Redelivery and seizure of imports for counterfeit certification marks (Federal Circuit decision)

10 Mar - Italy: Judicial proceedings in tax litigation, delayed deadlines in response to coronavirus (COVID-19)

9 Mar - OECD: Comments concerning 2020 review of country-by-country reporting

9 Mar - UK: Tax treaty network update

9 Mar - Vietnam: Managing tax audits

6 Mar - United States: IRS update to 2019-2020 priority guidance plan (second quarter)

5 Mar - Hong Kong: Arrangement for automatic exchange of country-by-country reports with China

5 Mar - Zambia: Disclosures required for related-party relationships

4 Mar - Luxembourg: Draft legislation to amend FATCA and CRS rules

4 Mar - South Africa: Tax authority to use transfer pricing risk profiling to verify compliance

4 Mar - Taiwan: Updated CRS reporting guidance

3 Mar - Hungary: Tax on advertising not precluded, but penalty regime held incompatible with EU law (CJEU judgment)

3 Mar - Nigeria: Status of implementation of BEPS recommendations

2 Mar - Argentina: Transfer pricing compliance rules, effective date delayed again

2 Mar - Czech Republic: Limitation on use of losses incurred in another EU country (CJEU judgment)

2 Mar - Italy: “Letters of intent” procedures, VAT relief for habitual exporters

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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