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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


November 2021

30 Nov - Nigeria: Extended deadline for waiver of interest and penalties on company tax liabilities

30 Nov - Belgium: New income tax treaty signed with France

30 Nov - Denmark: Changes to transfer pricing documentation requirements

30 Nov - Germany: Arm's length interest on intercompany loans (court decisions)

30 Nov - Japan: Overview of tax system

29 Nov - Japan: Updated FAQs under CRS regime

29 Nov - KPMG report: EU “public” country-by-country reporting and implications for multinational groups

26 Nov - KPMG report: Automating transfer pricing documentation

26 Nov - Australia: Transfer pricing and ATO report on “reportable tax position” schedule

24 Nov - Cyprus: DAC6 cross-border arrangements, reporting deadline again extended (31 January 2022)

24 Nov - United States and India: Agreement reached regarding “equalization levy” (digital services tax)

23 Nov - United States: Determining “immediate supervisor” for approving penalty when revenue agent has two different supervisors (U.S. Tax Court)

23 Nov - Canada: CRA to conduct audit to determine compliance with CRS and FATCA

23 Nov - EU: Infringement procedures and referrals to CJEU; European Parliament tax-related developments

23 Nov - UAE: Procedure for requesting penalty reconsideration

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2020

22 Nov - OECD: Peer review of automatic exchange of information (AEOI) published

22 Nov - UK: Transfer pricing items in HMRC annual report and accounts, 2020 to 2021

22 Nov - United States and Turkey announce digital services tax agreement

19 Nov - United States: House passes “Build Back Better Act” with tax measures

19 Nov - United States: Nonacquiescence to Eighth Circuit’s decision invalidating part of Reg. section 1.170A-9(c)(1), primary function of education organization (AOD 2021-4)

18 Nov - United States: IRA’s investment in coins, followed by taxpayer taking physical possession of the coins, held a taxable distribution (U.S. Tax Court)

18 Nov - KPMG report: Transfer pricing and factoring

18 Nov - Romania: Cancellation and reissuance of invoice, no implications for VAT refund period (CJEU judgment)

17 Nov - Chile: “Most favored nation” clause triggered under treaties with Canada and Mexico

17 Nov - Japan: Electronic recordkeeping requirements, performance-linked compensation measures under 2021 tax reform

17 Nov - South Africa: Penalties for individuals who fail to file tax returns

17 Nov - United States: IRS expands tax relief to all taxpayers in Mississippi affected by Hurricane Ida

17 Nov - United States: IRS updates “public key” for FATCA filing

16 Nov - United States: Inflation adjustments for information return penalties (Rev. Proc. 2021-45)

16 Nov - Switzerland: Considerations for transfer pricing year-end adjustments

15 Nov - Bermuda: Updated CRS compliance form guidelines

15 Nov - Colombia: Relief from interest and penalties for late payments of tax

15 Nov - Malta: Annual report for exchange of information under mandatory disclosure rules (DAC6)

15 Nov - United States: President signs bipartisan infrastructure bill, tax provisions are enacted

12 Nov - Romania: Standard audit file for tax, filing dates and implementation rules

12 Nov - India: Tax treatment of subscription fees for online databases and journals, tax treaty implications

12 Nov - Netherlands: Legislation addressing mismatches in application of arm’s length principle

11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting

11 Nov - KPMG report: Asia Pacific regional perspective on implementation of BEPS 2.0 as it relates to tax incentives

11 Nov - United States: “Build Back Better Act” tax proposals in pending House bill

10 Nov - EU: Developments from European Parliament, OECD and other international institutions

10 Nov - UAE: Clarification to tax procedure rules regarding taxpayer objections and appeals

9 Nov - Austria: Tax reform update; courts address treatment of reserved dividends, relief from double taxation; other developments

9 Nov - Singapore: Updated FAQs related to FATCA and CRS

9 Nov - United States: OFAC issues “finding of violation” to UAE bank regarding Sudan sanctions regulations

8 Nov - KPMG report: Managing multilateral controversy

8 Nov - Spain: Tax on increase in value of municipal land held unconstitutional (court decision)

5 Nov - United States: House passes bipartisan infrastructure bill with tax provisions, completing congressional action

5 Nov - Costa Rica: Local tax authorities to allow interest and penalty relief

4 Nov - Nigeria: Taxpayer’s deposit with FIRS found sufficient for tribunal’s jurisdiction

4 Nov - United States: JCT revenue estimate of tax provisions (as modified) in “Build Back Better Act”

3 Nov - United States: Expense allocation and apportionment in calculation of foreign tax credit limitation (IRS practice unit)

3 Nov - United States: IRS releases FAQs as reporting guidance for “carried interests”

3 Nov - Poland: Transfer pricing measures in “Polish Deal” legislation

2 Nov - Dominican Republic: Transfer pricing rules, updated compliance and documentation requirements

2 Nov - United States: Voluntary transfer pricing initiative in Louisiana

1 Nov - United States, EU agree to replace and suspend tariffs in steel and aluminum trade disputes

1 Nov - China: APA annual report provides statistics for 2020

1 Nov - Thailand: Automatic exchange of information (AEOI); actions by financial institutions expected beginning 2022

1 Nov - UAE: Tax procedural rules amended

October 2021

29 Oct - EU: Combined Nomenclature for 2022

29 Oct - South Africa: Assessments after three-year limitations period expired (court decision)

29 Oct - Switzerland: VAT treatment of vouchers (court decision)

28 Oct - Poland: Penalties for payment delays in commercial transactions

28 Oct - Slovakia: Paperless communication system between tax authorities and taxpayers

28 Oct - United States: House Rules Committee releases updated version of the “Build Back Better Act” (initial impressions)

27 Oct - Bermuda: Updated guidelines, CRS compliance certification form

27 Oct - United States: Senate Finance Chairman Wyden unveils “billionaires income tax”

27 Oct - United States: IRS expands tax relief, certain taxpayers in Mississippi affected by Hurricane Ida

27 Oct - United States: U.S. trade or business, permanent establishment; nonresident employee education expenses (IRS practice units)

26 Oct - United States: Senate Finance Chairman Wyden introduces “corporate profits minimum tax”

26 Oct - Australia: Fuel tax credit; substantiation using GPS technology

26 Oct - EU: Summary of tax-related developments, actions from CJEU and European Commission

26 Oct - Germany: Guidance regarding interest on tax underpayments and overpayments

25 Oct - Cayman Islands: CRS compliance updates

22 Oct - Ireland: Transfer pricing measures included in Finance Bill 2021

22 Oct - Mauritius: Financial Action Task Force (FATF) list of jurisdictions for increased monitoring

22 Oct - UK: Revised HMRC approach to correcting CJRS errors

21 Oct - India: Refund claims of GST by “special economic zone” unit

21 Oct - United States: Treasury statement regarding digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

20 Oct - Australia: ATO guidance on preparing for GST assurance reviews

20 Oct - Bahrain: Updated guidance on mutual agreement procedures

20 Oct - Thailand: Transfer pricing requirements and country-by-country reporting, effective 2021

19 Oct - Australia: Status of legislation to implement a reporting regime for the "sharing economy"

19 Oct - Poland: Legislation requiring e-invoices by 2023

18 Oct - United States: Alaska (failure to file electronically); Oregon (sales factor and foreign dividends); Texas (apportionment); Texas (sales tax nexus)

18 Oct - United States: LB&I video-conferencing for large business taxpayers

18 Oct - United States: Treasury’s review of sanctions

18 Oct - Cyprus: Arrangement with United States for exchange of country-by-country reports

18 Oct - OECD: Status update on BEPS Action 13 (country-by-country reporting) and Action 14 (mutual agreement procedure)

18 Oct - Oman: VAT guide for “special zones”

15 Oct - Serbia: Changes to tax procedure, tax administration rules

15 Oct - Thailand: Digital tax coupons for use and application against customs duties and taxes

15 Oct - United States: IRS clarifies FAQs may offer reasonable cause for penalty protection, but are not precedential

15 Oct - United States: IRS sets forth required information for valid research credit claim for refund (Chief Counsel legal advice memo)

15 Oct - United States: Sanctions compliance guidance for virtual currency industry

14 Oct - Austria: Transfer pricing guidelines 2021 are finalized

14 Oct - India: Unused foreign tax credit; “fees for technical services” under Singapore tax treaty

14 Oct - Serbia: Updated transfer pricing guidance, information for country-by-country report

14 Oct - Vietnam: Guidelines on APA program changes

13 Oct - OECD: G20 finance leaders endorse changes to global tax rules

13 Oct - Australia: Proposed expansion of tax treaty network

13 Oct - Czech Republic: Arm’s length price, advertising as a deductible expense (court decision)

13 Oct - Czech Republic: Burden of proof, taxable and VAT-exempt services

13 Oct - France: VAT and mandatory e-invoicing; new effective date of 1 July 2024

11 Oct - EU: CJEU judgments and referrals, infringement procedures, other developments

11 Oct - Finland: Tax-exemption regime for investment funds, possible refund opportunity (CJEU Advocate General opinion)

11 Oct - Nigeria: Late-filing penalty and interest relief for companies, through 30 November 2021

11 Oct - UAE: User guide for appeals under economic substance regulations

11 Oct - UK: Closure notices for transfer pricing enquiries, despite ongoing diverted profits tax review (First-tier Tribunal)

8 Oct - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy

7 Oct - Nigeria: New procedural rules adopted for tax appellate tribunal

7 Oct - Saudi Arabia: Draft VAT legislation proposes changes for e-invoicing

7 Oct - Thailand: New requirements for transfer pricing and Local file documentation

7 Oct - United States: Form 1099-NEC added to the combined federal-state filing program

7 Oct - United States: No change to list of countries cooperating with international boycott

7 Oct - United States: IRS TE/GE compliance priorities, 2022 program letter

6 Oct - United States: FBAR filing deadline relief for persons affected by certain natural disasters

6 Oct - Czech Republic: Proposed implementation of directive for income earned by digital platforms (DAC7)

5 Oct - EU: Updates to list of non-cooperative jurisdictions

4 Oct - KPMG report: Country-by-country reporting, notification requirements per country

4 Oct - United States: Examining a reseller’s section 263A computation (IRS practice unit)

1 Oct - Bermuda: CRS compliance certification form for 2020 due 15 December 2021

1 Oct - Poland: Updated proposals for changes to withholding tax collection rules

September 2021

30 Sep - Hong Kong: Added to EU “grey list” for tax purposes

30 Sep - UAE: Updated FAQs under CRS regime

30 Sep - United States: High court upholds B&O tax surcharge on banks (Washington State)

30 Sep - KPMG report: LIBOR transition, transfer pricing considerations of intercompany financial arrangements

29 Sep - KPMG report: Managing transfer pricing and customs risks of cross-border transactions

29 Sep - Cyprus: Extension of filing date for income tax returns for 2019, companies and self-employed

29 Sep - Germany: Interest rate of 6% for tax deficiencies, refunds held unconstitutional

29 Sep - Jordan: Instructions for implementing transfer pricing regime include documentation requirements

28 Sep - United States: House Budget Committee’s report on “Build Back Better Act” (the reconciliation bill)

28 Sep - United States: Updated list of countries, deposit interest paid to nonresident aliens (Chile, Dominican Republic, Singapore)

28 Sep - EU: Update on "public" country-by-country reporting

28 Sep - Channel Islands: Amendments to FATCA and CRS regulations (Guernsey)

27 Sep - Switzerland: Arm’s length price and transfer pricing implications of financial guarantees

27 Sep - Germany: Application of EU Parent-Subsidiary Directive when partnership acts as intermediary (court decision)

27 Sep - Germany: Attribution of profits of permanent establishment without personnel (court decision)

27 Sep - United States: Companies agree to settle violations of Ukrainian and Sudanese sanctions

24 Sep - EU: CJEU actions in tax cases; other tax-related actions of EU institutions 

22 Sep - United States: Resource and information about refunds subject to review by Joint Committee on Taxation (IRS webpage)

22 Sep - United States: Senate approves Assistant Secretary for Tax Policy

22 Sep - British Virgin Islands: FATCA reporting obligations, U.S. TIN information is mandatory

22 Sep - Netherlands: Proposal to address mismatches in non-arm’s length transfer pricing

22 Sep - Saudi Arabia: Merger of tax and customs authorities is completed

21 Sep - Cyprus: Effective date of tour operators’ margin scheme (court decision)

20 Sep - Austria: Approaching deadline of 30 September for claiming investment premium for fixed assets, for VAT refunds; standard audit file update

20 Sep - Belgium: Treaty relief with Luxembourg, for cross-border workers

20 Sep - Bermuda: Compliance actions under CRS requirements

20 Sep - Germany: Updated CRS guidance, self-certification

20 Sep - Hong Kong: Taxation of share grants when subject to forfeiture provisions (court decision)

20 Sep - Poland: “Executed tax strategy” reporting requirements, include transfer pricing information

20 Sep - Singapore: Determining when certain machinery is excluded from property tax (court decision)

20 Sep - United States: IRS acceptance of non-traditional real property (such as fiber optic cable) for REIT income tests

17 Sep - Czech Republic: Vacation rentals via online marketplace held business activity, not property lease

16 Sep - Belgium: Excess profit ruling system and state aid scheme (CJEU judgment)

16 Sep - Netherlands: Updated FATCA and CRS guidance

16 Sep - Peru: Approaching deadline for secondary filing by U.S. multinationals of FY 2020 country-by-country reports

16 Sep - Serbia: Key dates for implementing tax administrative measures

16 Sep - United States: Tax proposals for budget reconciliation legislation approved by Ways and Means

16 Sep - United States: Section 263A costs for self-constructed assets; limitation of exchange gain or loss (IRS practice units)

15 Sep - EU: Energy taxation directive

15 Sep - Nigeria: Rivers State government asks high court to dismiss order staying VAT enforcement

15 Sep - Spain: Deadline to claim VAT refund for 2020 is 30 September 2021

14 Sep - Indonesia: Ratification of tax treaties with UAE and with Singapore

14 Sep - Namibia: Transfer pricing adjustments when transaction not at arm’s length

13 Sep - United States: JCT estimated budgetary effects, technical explanation of revenue-raising Ways and Means proposals

13 Sep - United States: Ways and Means releases additional proposals for markup, including tax increases

13 Sep - Nigeria: Court of Appeal orders Nigerian states to maintain status quo on VAT administration

13 Sep - Singapore: New release of transfer pricing guidelines

13 Sep - Taiwan: Customs requirements when making one-time transfer pricing adjustments

13 Sep - UK: HMRC guidance on disclosing coronavirus job retention scheme (CJRS) claims

10 Sep - Kenya: Effect of late filing of VAT returns on input VAT claims (High Court decision)

10 Sep - Nigeria: Authority of states to collect stamp taxes (duties)

10 Sep - United States: IRS Priority Guidance Plan for 2021-2022

10 Sep - United States: Senate Finance Committee chairman releases discussion draft on reforming taxation of passthrough entities

9 Sep - United States: Company to pay $189,000 to settle violations of Iranian sanctions

9 Sep - United States: Determination, disposable gloves from Malaysia not produced by forced labor

8 Sep - Thailand: Reduced withholding tax for payments made via e-withholding system extended through 2022

8 Sep - Cayman Islands: Updated FATCA and CRS guidance

8 Sep - Nigeria: VAT legislation introduced (Lagos State)

7 Sep - Nigeria: Rivers State government orders implementation of state VAT law

7 Sep - Ukraine: Draft legislation concerning the digital economy

7 Sep - United States: Draft forms and instructions in W-8 series

7 Sep - United States: Ways and Means announces first part of budget reconciliation markup, includes qualified plan proposals

3 Sep - United States: Penalty for failure to deposit taxes under CARES Act (Chief Counsel legal advice memo)

3 Sep - Botswana: Threshold for preparing and filing transfer pricing documentation

2 Sep - Cayman Islands: Updated portal user guide

2 Sep - India: Indirect transfer-related provisions; due dates of electronic filing of forms extended

2 Sep - Malaysia: Study of special voluntary disclosure program for indirect tax

1 Sep - United States: Foreign tax credit (business) general principles (IRS practice unit)

1 Sep - Kazakhstan: “Pilot project” on electronic VAT invoicing exemption

1 Sep - Serbia: Rules relating to electronic invoicing (e-invoicing)

1 Sep - Taiwan: Guidance on application of income tax treaties amended

August 2021

31 Aug - EU: CJEU judgment and referrals, infringement procedures, other developments

31 Aug - EU: Transitional preferential rules of origin under pan-Euro-Mediterranean (PEM) Convention

31 Aug - Germany: Interest rate of 6% for back taxes and tax refunds unconstitutional

31 Aug - Germany: New administrative guidelines for transfer pricing

31 Aug - Hong Kong: Updated AEOI self-certification template for “controlling persons”

31 Aug - Ireland: Updated filing guidelines under CRS regime

31 Aug - Taiwan: CRS data for 2020

30 Aug - Nigeria: VAT, other taxes outside jurisdiction of federal government (Federal High Court)

30 Aug - UK: Draft guidance on uncertain tax treatments

30 Aug - UK: Estoppel by convention used by HMRC (Supreme Court decision)

26 Aug - United States: UK financial institution agrees to pay $2.3 million to settle Sudan sanction violations

25 Aug - United States: Senate Finance Committee chairman, Democratic members: Discussion draft on overhauling U.S. international taxation

25 Aug - United States: Interest rates, tax underpayments and overpayments (no changes for fourth quarter 2021)

25 Aug - Cayman Islands: CRS compliance form deadline

25 Aug - KPMG report: Digitalization driving new operating models for financial services industry; transfer pricing considerations

24 Aug - United States: House passes budget resolution; implications for major tax legislation

24 Aug - United States: Revised applicability date, withholding and reporting regarding publicly traded partnership interests

24 Aug - United States: Transfers of property to partnerships; accuracy-related penalty and reportable transactions (IRS practice units)

23 Aug - United States: Colorado (federal tax conformity); North Carolina (sourcing, asset management services); Texas (sourcing, satellite radio service)

23 Aug - United States: IRS opens application period for 2022 Compliance Assurance Process (CAP) program

23 Aug - India: Payments for use of online advertising, marketing, and IT facilities not taxable as royalties under tax treaties

20 Aug - Germany: Updated CRS guidance

19 Aug - Chile: Guidance regarding tax examinations

17 Aug - Australia: Corporate tax transparency data to be published

17 Aug - India: Activities constituting PE under tax treaty with Norway; treaty benefits on company’s re-domiciliation

17 Aug - India: Tax relief, computation when book profit increase due to APA or secondary adjustments

16 Aug - United States: Treaty provisions do not allow foreign tax credit offset against net investment income tax (U.S. Tax Court)

12 Aug - United States: Senate infrastructure bill would expand cryptocurrency tax reporting

12 Aug - Netherlands: Increased monitoring of import declarations by Dutch Customs

11 Aug - Bahrain: Economic substance information returns due 31 August 2021

11 Aug - Czech Republic: Tax treatment of disposal costs of assets (Supreme Administrative Court decision)

11 Aug - Czech Republic: Transfer pricing issues remain under scrutiny

11 Aug - United States: Senate passes budget resolution; implications for major tax legislation

10 Aug - United States: Senate approves infrastructure bill, including tax provisions

10 Aug - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 16 August

10 Aug - China Customs streamlines penalty provisions

9 Aug - United States: California company to pay $6.6 million penalty for software exports violating U.S. arms regulations

9 Aug - Hong Kong: Guidance addresses tax residence, permanent establishment, cross-border employee issues

9 Aug - Vietnam: Updated FATCA guidance

6 Aug - India: Capital gains on transfers of shares of foreign company; due dates for electronic filing extended

6 Aug - South Africa: Proposal to address tax avoidance on wealth transfers to certain trusts by individuals

5 Aug - South Africa: Proposed penalty regime, individual taxpayers not filing income tax returns

5 Aug - Luxembourg: Transposition of EU directive, cross-border distributions of collective investment undertakings

5 Aug - OECD: Countries bring preferential tax regimes in line with international standards

5 Aug - Panama: FATCA reporting deadline extended to 15 August 2021

4 Aug - United States: Penalty for failure to include reportable transaction information (IRS practice unit)

4 Aug - India: Long-term capital loss on sale of shares by foreign company allowed, not sham transaction

4 Aug - Mauritius: Income tax treaty with Lesotho

3 Aug - OECD: Transfer pricing country profiles; updated for financial transactions and permanent establishments

3 Aug - Australia: Common loss carryback errors identified

3 Aug - Mexico: Extension of time, outsourcing personnel rules

3 Aug - UK: Tax on overseas dividends, reliefs, interest (Supreme Court decision in FII group litigation)

3 Aug - United States: Competent authority arrangements on derivative benefits under income tax treaty with United Kingdom

2 Aug - United States: Senate releases legislative text of bipartisan infrastructure bill

2 Aug - Bulgaria: Income tax treaty with the Netherlands

2 Aug - China: Simplified procedure for unilateral APAs

2 Aug - Japan: Protocol to amend income tax treaty with Switzerland

July 2021

30 Jul - UK: Large businesses required to disclosure uncertain tax treatment in tax returns

30 Jul - Mauritius: Extended deadline for FATCA and CRS reporting

29 Jul - Poland: Transfer pricing measures in proposed tax legislation

28 Jul - United States: IRS scrutiny of hospitals’ net operating losses

28 Jul - United States: Overview of section 987 and branch operations in a foreign currency (IRS practice unit)

28 Jul - United States: Treaty claims and Form W-8BEN-E

28 Jul - Canada: Temporarily suspended limitation periods to resume 1 September 2021 (Quebec)

28 Jul - EU: CJEU judgment and EFTA referral, state aid ruling, other developments

28 Jul - Hungary: Delayed implementation date, tentative VAT returns prepared by tax authority

27 Jul - India: Advertisement and sales promotion, post-import activity and not includible in assessable value of imports (Supreme Court decision)

26 Jul - United States: Indiana (franchise fee litigation); Michigan (advertising materials)

26 Jul - United States: IRS revises system for filing information returns electronically

21 Jul - United States: Electronic-filing requirements for specific tax returns, other documents (proposed regulations)

21 Jul - Costa Rica: Change to taxpayer status for failures to file returns

20 Jul - Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance

20 Jul - Hong Kong: Restricted shares issued under termination agreement not subject to salaries tax (court decision)

19 Jul - Netherlands: Interest deduction denied in acquisition structure (Dutch Supreme Court)

19 Jul - Sri Lanka: Transfer pricing rules, documentation requirements

19 Jul - U.S. and UAE companies agree to settle violations of Iranian sanctions

19 Jul - United States: Arizona (digital data); California (SALT cap work-around); Oregon (corporate activity tax)

16 Jul - United States: Section 482 adjustments for cost-sharing agreements with reverse claw-back provisions (Chief Counsel legal advice memo)

16 Jul - EU: Infringement proceedings and referrals to CJEU, other developments

15 Jul - Bahrain: Country-by-country reporting and notification obligations

15 Jul - Oman: Clarification of suspension of country-by-country reporting

14 Jul - Netherlands: Formal investigation of tax rulings, transfer pricing issues (EU General Court)

13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021

13 Jul - Panama: List of reportable jurisdictions updated; CRS reporting deadline extended

13 Jul - Romania: Guide for new tax reporting procedure

13 Jul - Russia: Transfer pricing audits, focus on pre-audit analysis

13 Jul - Nigeria: Tax assessment upheld, retroactive reduction of “tax holiday” for petroleum companies (tribunal decision)

13 Jul - Seychelles: Tax amnesty available through December 2021

12 Jul - EU: European Commission expected to act swiftly once global agreement is reached; G20 Finance Ministers endorse key components of the two pillars

12 Jul - Netherlands: Interest deduction on group loan, hybrid elements in group structure (Supreme Court judgment)

10 Jul - G20 Finance Ministers conclude meeting with agreement for global minimum tax, other measures

9 Jul - United States: FDII and computing qualified research expenses (IRS practice units)

8 Jul - United States: Five-year suspension of tariffs, large civil aircraft disputes with EU and UK

8 Jul - Oman: Country-by-country reporting is suspended

6 Jul - Japan: Updated guidance (Q&As) under group relief system

6 Jul - Madagascar: Transfer pricing documentation requirements

2 Jul - United States: Foreign tax redeterminations (IRS practice unit)

2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0

2 Jul - United States: Ways and Means, Finance chairs express support for global minimum tax

2 Jul - Canada: Guidance on obtaining Competent Authority assistance, MAP requests and transfer pricing adjustments

2 Jul - Finland: Updated FATCA guidance concerning U.S. TINs

1 Jul - EU: European Commission consultations, European Parliament hearings, ECOFIN report (July 2021)

1 Jul - OECD: Statement of Inclusive Framework on two-pillar solution addressing tax challenges of digital economy

1 Jul - United States: California’s requirements for disclosure of identities of donors violates First Amendment (U.S. Supreme Court)

June 2021

30 Jun - Germany: Legislation transposing ATAD measures (exit taxation, CFC rules, hybrid mismatches)

30 Jun - Germany: Provisions amending arm’s length principle, transfer pricing

30 Jun - United States: Allocation methods of personal use of aircraft (IRS practice unit)

29 Jun - United States: IRS memorandum on TE/GE exam activities

29 Jun - Liechtenstein: CRS and FATCA controls for managed legal entities, banks and insurance companies

29 Jun - Singapore: GST implications of common transfer pricing adjustments

29 Jun - South Africa: Transfer pricing adjustments and implications for VAT purposes

28 Jun - Brazil: Second phase of tax reform proposals are outlined

28 Jun - EU: Changes to VAT rules affecting cross-border e-commerce effective 1 July 2021

28 Jun - Germany: Updated FATCA, CRS guidance

28 Jun - Jordan: Transfer pricing regulations are introduced

28 Jun - Ukraine: Income tax and VAT implications of intra-group services

25 Jun - Australia: ATO revises guidance on tax treatment of software royalties

25 Jun - Austria: The right to use software can qualify as VAT-exempt asset management (CJEU judgment)

25 Jun - Azerbaijan: Update on country-by-country reporting

25 Jun - Liechtenstein: Updated FATCA guidance

24 Jun - United States: IRS releases tax collection data for fiscal year 2020

23 Jun - Ireland: Updated guidance on treatment of profit-sharing plans for FATCA, CRS purposes

22 Jun - Germany: Updated CRS guidance

22 Jun - Isle of Man: Economic substance rules extended to partnerships

22 Jun - OECD: Reporting rules for platform operators regarding sellers in “sharing and gig economy”

21 Jun - United States: Illinois (manufacturing exemption); Iowa (bonus depreciation); New York State (non-filer liability); Texas (marketplace facilitator)

21 Jun - Finland: Updated CRS technical guidance

21 Jun - Qatar: Deadline for filing Master files and Local files extended to 30 September 2021

18 Jun - Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures

18 Jun - Malaysia: Common transfer pricing issues arising from intra-group services

18 Jun - UK: Tax tribunal decision confirming tax deductibility of deferred revenue expenditure

18 Jun - Channel Islands: Economic substance and partnerships (Guernsey)

18 Jun - United States: IRS practice unit: Concepts of GILTI

17 Jun - United States: Implications for protective refund claims for ACA-related taxes and fees (U.S. Supreme Court)

17 Jun - United States, United Kingdom to suspend trade countermeasures for five years, large civil aircraft dispute

16 Jun - United States: House passes bill requiring country-by-country reporting of pre-tax profits, taxes paid

16 Jun - United States: Scheduled outage of FATCA systems

15 Jun - EU: Update on status of “public” country-by-country reporting

15 Jun - Finland: Updated FATCA technical guidance

15 Jun - Sweden: Interest-deduction limitation rules contrary to EU law; EC formal notice

15 Jun - United States: Free trade agreement between Australia and UK

14 Jun - United States: Colorado (marketplace facilitator); Nevada (mining excise tax); Nevada (business tax refunds); Vermont (taxable meal facilitator); Washington State (payroll tax, B&O surcharge)

14 Jun - United States: Permanent establishment-related considerations, employees working remotely

14 Jun - United States: Treasury releases the American Families Plan tax compliance agenda

11 Jun - China: Instructions for submitting CRS annual reports

11 Jun - Kenya: Country-by-country reporting proposal in budget 2021-2022

11 Jun - Spain: Final rules for digital services tax; first declaration is due July 2021

11 Jun - United States: Nonacquiescence to Eleventh Circuit decision, professional employer organization’s claims for FICA credits (AOD 2021-3)

11 Jun - United States: Partner’s outside basis (IRS practice unit)

10 Jun - United States: IRS adds a new compliance campaign (LB&I division)

10 Jun - United States: Mandatory 60-day postponement of tax deadlines, federally declared disasters

10 Jun – United States: Senate Finance Committee approves Treasury Department officials, including Assistant Secretary for Tax Policy

10 Jun - Nigeria: Guidance for filing naira-denominated tax returns electronically

9 Jun - Barbados: Deadline to file 2020 FATCA, CRS returns extended to 31 July 2021

9 Jun - Cayman Islands: Updated FATCA and CRS guidance

9 Jun - Czech Republic: Status of digital services tax legislation

8 Jun - EU: G7 communique on coordinated reforms of international tax system, European perspective

8 Jun - Netherlands: Termination of income tax treaty with Russia

8 Jun - Switzerland: Implications of EU “public” country-by-country reporting for Swiss groups

8 Jun - Thailand: Monthly tax return filing, payment deadlines extended

7 Jun - Cyprus: DAC 6 cross-border arrangements, reporting deadline extended to 30 September 2021

7 Jun - Japan: Requirements for electronic recordkeeping of tax-related books and records

Jun 7 - KPMG report: Analysis and observations about tax measures in G7 communique

7 Jun - Saudi Arabia: Guidelines and standards for e-invoices

7 Jun - United States: New Jersey (Public Law 86-272); New Jersey (NOL carryforward); Maryland (digital advertising services); Tennessee (sales tax holiday); multistate (corporate tax rate reductions)

4 Jun - United States-Switzerland: Competent authorities add individual savings plans as eligible for dividend benefits under tax treaty

4 Jun - Cyprus: Income tax treaty with the Netherlands

3 Jun - India: GST Council recommends reducing compliance burden

3 Jun - Malaysia: Penalty relief for late payment of GST; service tax exemption for joint development area

3 Jun - Qatar: Reminder of deadlines for tax returns for 2020

2 Jun - United States: Taxpayer not a “bank” and thus not allowed to deduct certain losses (Fifth Circuit)

2 Jun - United States: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed) (Ninth Circuit)

2 Jun - EU: Political agreement on “public” country-by-country reporting requirements

2 Jun - France: Updated FATCA technical guidance

2 Jun - Taiwan: CRS reporting deadline extended to 2 August 2021

1 Jun - Argentina: Proposal to revise corporate income tax rates, pending in Congress

1 Jun - Australia: Evidence relevant for determining arrangements are at arm’s length (High Court decision)

1 Jun - EU: State aid determinations, referrals to CJEU, other developments

1 Jun - Germany: Cross-border company “split-up” (court decision of first impression)

1 Jun - Poland: Tax proceedings initiated to suspend limitations period; identifying rental and lease revenue

1 Jun - UAE: Clarifications about tax penalty regime

May 2021

31 May - United States: Analysis and observations of tax proposals in Biden Administration’s FY 2022 budget

28 May - United States: Initial impressions of tax proposals in Biden Administration’s budget for FY 2022

28 May - United States: Green Book—Treasury’s explanation of tax proposals in FY 2022 budget

28 May - United States: Biden Administration’s budget proposals for FY 2022

28 May - Bahrain: Economic substance returns, deadline extended to 31 July 2021

28 May - Channel Islands: Economic substance rules for partnerships (Jersey)

28 May - Ireland: Updated filing guidelines for FATCA

28 May - KPMG report: Comments on proposed changes to Commentaries in OECD Model Tax Convention, Article 9 and related articles

28 May - Brazil: Status of possible transfer pricing rules

28 May - Hong Kong: What are possible considerations for BEPS 2.0?

28 May - Taiwan: Amended CRS measures

27 May - India: FATCA and CRS reporting deadlines extended to 30 June 2021

26 May - South Africa: Documentation for interest-free or low-interest loans involving trusts

26 May - Ukraine: Withholding tax rates under tax treaty and “principal purpose test” (court decision)

25 May - United States: FATCA responsible officer certifications due 1 July 2021

25 May - Barbados: AEOI web portal for FATCA and CRS filings, open until 1 June 2021

25 May - Channel Islands: No deadline changes for FATCA and CRS reporting (Guernsey)

25 May - Germany: Updated FATCA guidance

25 May - Malta: Country-by-country reporting, penalties for non-compliance

25 May - Saudi Arabia: Tax and customs authorities merge into single authority

25 May - UK: Supreme Court dismisses HMRC’s appeal; “staleness” and discovery assessments

24 May - EU: Consultation on rules to neutralize misuse of shell entities; recommendation on domestic tax treatment of losses

24 May - Italy: Updated list of reportable, participating jurisdictions for AEOI under CRS regime

24 May - Nigeria: Suspended country-by-country reporting requirements for MNE branches and subsidiaries

24 May - Thailand: Proposed temporary reduction of customs duty surcharge for inadvertent underpayments

24 May - United States: Missouri (remote sellers, marketplace facilitators); Indiana (pharmacy benefits management); Nevada (modified business tax rate)

24 May - United States: Allocation and apportionment of deductions, individual taxpayers (IRS practice unit)

20 May - United States: Tax reform proposals—BEAT down, SHIELD up

20 May - United States: Treasury’s report on proposed tax compliance measures; addressing the “tax gap”

20 May - United States: Treasury officials participate in OECD meetings, proposal for global corporate minimum tax rate

20 May - Channel Islands: FATCA and CRS updates (Jersey)

20 May - India: Amendments to GST refund rules and procedures

20 May - India: “Faceless” audits and future rules expected for transfer pricing audits

20 May - Kenya: Country-by-country proposals in Finance Bill, 2021

20 May - Luxembourg: Updated CRS FAQs

20 May - Tanzania: Rendering of intra-group services and transfer pricing audits

20 May - Australia: Intangibles arrangements; a deeper look at ATO’s draft practical compliance guideline

19 May - Australia: Draft compliance guideline, transfer pricing and international arrangements involving intangible assets

19 May - EU: Analysis of proposed business tax framework

19 May - Qatar: FAQs address transfer pricing documentation

18 May - Bahrain: FAQs on country-by-country reporting

18 May - Barbados: AEOI portal for FATCA and CRS reports, open until 31 July 2021

18 May - Belgium: Tax administration focuses on directors, executives with management responsibilities at foreign company

18 May - EU: CJEU, European Commission, European Parliament updates; state aid rulings (May 2021)

18 May - Poland: Transfer pricing documentation, preliminary agreements and tax haven-related transactions

18 May - Serbia: Measures revising tax treatment of independent contractors

18 May - Singapore: CRS guidance concerning qualifying personal investment companies

17 May - India: Effects of APA on taxable income (royalty) received by foreign taxpayer that is not a party to the APA

17 May - Mexico: List of registered foreign providers of digital services

17 May - United States, EU agree to address steel and aluminum trade issues, customs duties

17 May - United States: CBP headquarters ruling; cotton garments produced in part by forced labor in China

14 May - United States: Updated FAQs provide default codes for missing U.S. TINs

13 May - United States: Eighth Circuit reverses district court, finds regulations are valid

13 May - Finland: Withholding tax refunds claimed by Luxembourg SICAV; potential refund opportunities (CJEU judgment)

13 May - Bulgaria: Transfer pricing documentation; Local file for 2020 required by 30 June 2021

13 May - Canada: Changes to filing procedure for corporate information returns (Ontario)

13 May - Serbia: New electronic invoicing law, VAT implications

13 May - Panama: Default TINs for FATCA reporting

12 May - Czech Republic: Tax treatment of interest on acquisition loan in intragroup restructuring (court decision)

12 May - Luxembourg: Tax rulings provided no selective advantage (EU General Court)

12 May - Luxembourg: Tax rulings granted to companies resulted in tax advantage (EU General Court)

12 May - Singapore: Transfer pricing guide for multinational entity headquarters

12 May - Taiwan: Rules allowing one-time transfer pricing adjustment

12 May - United States: Proposal to require country-by-country reporting of pre-tax profits, taxes paid

11 May - United States: CFCs changing methods of accounting to alternative depreciation system

11 May - KPMG report: Overview of R&D tax incentives, by country (2021)

11 May - EU: New export controls for “dual-use” goods and technologies

11 May - EU: Update on initiatives for public and non-public country-by-country reporting

11 May - KPMG report: Country-by-country reporting; notification requirements per country (updated)

11 May - Nigeria: Tax collection agents reminded to remit taxes collected by deadline

11 May - Saint Kitts and Nevis: Possible extension of CRS reporting deadline

11 May - Serbia: Tax administrative measures effective in 2022

10 May - UAE: Tax-related penalty regime revised

7 May - Bahrain: New electronic filing requirement for economic substance returns

7 May - China: CRS reporting deadline extended to 16 June 2021

6 May - Bermuda: CRS reporting deadline extended to 30 June 2021

6 May - Canada: APA statistics for 2020

6 May - EU: Resolution of European Parliament on taxing digital economy

6 May - Thailand: Extended deadline for corporate income tax return filing, payment

5 May - Liechtenstein: FATCA, CRS reporting deadline extended to 31 July 2021

5 May - Philippines: Updated guidelines for tax treaty relief

5 May - Spain: Transposition of EU directive (DAC 6) completed

5 May - Taiwan: CRS reporting deadline 30 June 2021; new information

4 May - India: Tax treatment of items under income tax treaties with Singapore and the Netherlands

4 May - Kenya: Marketing support services for non-resident entities, zero-rated for VAT purposes (tribunal decision)

4 May - United States: Company to pay $13 million to settle alleged ITAR export violations

4 May - United States: FATCA IDES testing, scheduled for June 2021

3 May - United States: Arkansas (sales tax exemption); Arkansas (NOL add-back); Florida (federal tax conformity); New York City (sale of partnership interest); Washington State (excise tax, capital gain)

3 May - United States: USTR hearings this week, investigations of digital services taxes

3 May - United States: Valuation of performer’s image and likeness, music publishing trust and catalog (U.S. Tax Court)

April 2021

30 Apr - United States: IRS automatically extends QI / WP / WT certification and waiver application due dates

30 Apr - United States: Treatment of expenses related to aircraft owned and used by sole proprietor (IRS Chief Counsel memo)

30 Apr - United States: Schedules K-2 and K-3 for 2021; intended for enhanced reporting of international tax matters by pass-through entities

30 Apr - Singapore: R&D expenses under cost-sharing agreement (appellate court decision)

30 Apr - EU: Actions by and referrals to CJEU, European Parliament and EU Council

29 Apr - Saudi Arabia: Force of attraction rules in relation to permanent establishments

29 Apr - Vietnam: Default TINs for FATCA reporting

29 Apr - United States: Updated list of jurisdictions not issuing foreign TINs

28 Apr - United States: President Biden announces American Families Plan, individual tax proposals

28 Apr - United States: Treasury proposals for tax administration reforms

27 Apr - United States: House Ways and Means chair introduces economic plan, includes tax provisions

27 Apr - United States: Legal expenses for FDA approvals capitalized, but those for defending patent infringement suits are deductible (U.S. Tax Court)

27 Apr - Kenya: Application of commercial building allowance for years before 2010 (High Court decision)

27 Apr - Switzerland: New income tax treaty with Brazil

27 Apr - British Virgin Islands: FATCA, CRS deadlines extended to 30 June 2021

27 Apr - Kenya: No withholding tax on payments to South African entity under income tax treaty

26 Apr - Australia: Additional default TIN under FATCA regime

26 Apr - Poland: “Ready-to-eat meals” subject to reduced VAT rate (CJEU judgment)

26 Apr - United States: Arizona (federal tax conformity); Illinois (unitary group); Texas (R&D tax credit); Vermont (federal tax conformity)

23 Apr - Belgium: New XML scheme for filing reports related to mandatory disclosure rules (DAC 6)

23 Apr - Malta: Tax returns for 2020, filed by fiscal units

23 Apr - UK: Commercial transaction structured in tax-efficient way not “main purpose” of tax avoidance (tax tribunal decision)

23 Apr - Costa Rica: Income tax treaty with UAE

22 Apr - Cayman Islands: Updated FATCA and CRS guidance

22 Apr - Gibraltar: Process for determining whether legal entities are residents of Spain

22 Apr - Luxembourg: “Zero-value message” filings under FATCA and CRS regimes

22 Apr - United States: Marijuana dispensary’s claimed expenses properly denied (Ninth Circuit)

22 Apr - EU: Review of deemed supply rules for online marketplaces, effective 1 July 2021

21 Apr - EU: Summary of CJEU referrals and judgments; EC actions, country updates (April 2021)

21 Apr - Kenya: Tax authority temporarily restrained from collecting minimum tax

21 Apr - Malta: FATCA, CRS reporting deadlines extended to 30 June 2021

20 Apr - Bahrain: FATCA and CRS reports for 2020 due 31 May 2021

20 Apr - Canada: Tax measures in 2021 federal budget

20 Apr - Malta: Update on expectations for transfer pricing rules

20 Apr - Poland: VAT penalty of 20% held incompatible with EU law (CJEU judgment)

19 Apr - Finland: Updated FATCA and CRS technical guidance

19 Apr - Germany: Insurance premium tax for seagoing vessels (CJEU judgment)

19 Apr - United States: Company agrees to pay $435,000 for imports of engineering services from Iran

19 Apr - United States: Florida (tobacco tax); Maryland (reseller basis for refund); Virginia (reporting unitary combined income)

19 Apr - United States: IRS allows temporary relief from handwritten signature requirement for more tax forms

16 Apr - Singapore: CRS returns for 2020 due by 31 May 2021

16 Apr - Singapore: Guidelines for tax treatment of transactions involving digital tokens

15 Apr - Japan: New FAQ added under CRS regime

15 Apr - Luxembourg: VAT exemption, legal services for adults lacking legal capacity (CJEU judgment)

15 Apr - Nigeria: Transfer pricing awareness survey (KPMG report)

15 Apr - Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures

15 Apr - United States: JCT overview of federal tax system (2021)

15 Apr - United States: Taxation of digital advertising services; sales and use tax on digital products and services (Maryland)

14 Apr - Argentina: New digital services tax procedures for Buenos Aires

14 Apr - Brazil: Review of digital services tax proposals

14 Apr - United States: Recommendations for IRS 2021-2022 Priority Guidance Plan

14 Apr - United States: Updated charts reflecting provisions in President Biden’s business tax proposals

13 Apr - United States: Penalty relief, reduced federal employment tax deposits in anticipation of tax credits

13 Apr - Pakistan: Implications of MLI on income tax treaties

13 Apr - Italy: Withholding tax exemption, interest payed to UK banks during Brexit transition period; possible refund opportunities

13 Apr - Netherlands: Acquisition of real estate legal entity subject to real estate transfer tax

12 Apr - Chile: Tax implications of asset transfers in corporate dissolutions

12 Apr - United States: Maryland (digital advertising, digital products); New York City (services sourcing); Ohio (IP sourcing); West Virginia (apportionment)

12 Apr - United States: Split-dollar arrangement distributions; benefits under compensatory arrangement taxable as ordinary income (U.S. Tax Court)

9 Apr - United States: IRS nonacquiescence, defined benefit pension plan not an asset for insolvency exclusion under section 108 (AOD 2021-1)

9 Apr - United States: IRS reminder, FBAR filing deadline remains 15 April

9 Apr - Belarus: Review of transfer pricing measures effective in 2021

9 Apr - Cayman Islands: Updated FATCA and CRS guidance

9 Apr - UK: Proposals for new transfer pricing documentation, new annual related-party transaction return

9 Apr - Zambia: Amendments to country-by-country reporting rules

8 Apr - Costa Rica: Advance pricing agreements, implementing guidance

8 Apr - Italy: Relief measures suspend tax collection, extend digital services tax deadlines

8 Apr - Poland: Rate of property tax, real estate not used in business activity (tribunal decision)

7 Apr - Malta: Updated FATCA, CRS guidance regarding AEOI

7 Apr - OECD: Report on status of international tax agenda, developments

7 Apr - Singapore: Updated FATCA guidance and FAQs

7 Apr - United States: Treasury releases report “Made in America Tax Plan”

6 Apr - United States: Foreign tax credit carryback and carryover (IRS practice unit)

6 Apr - Oman: Guidance concerning administrative tax disputes and VAT zero-rating for medicines

5 Apr - EU: Summary of CJEU judgments, referrals (April 2021)

5 Apr - Finland: Updated FATCA and CRS technical guidance

5 Apr - Liechtenstein: Updated AEOI guidance

5 Apr - United States: IRS TE/GE division announces new compliance initiatives

5 Apr - United States: Presidential proclamation imposing tariffs on steel “derivatives” held invalid (U.S. trade court)

5 Apr - United States: Senate Finance Committee chairman, Democratic members: Framework on overhauling U.S. international taxation

2 Apr - United States: Liquidating distributions of partner’s interest; reasonable cause and good faith (IRS practice units)

2 Apr - Nigeria: Automated tax system deployed

2 Apr - Russia: Tax audits of individuals with foreign-held assets, accounts

2 Apr - Netherlands: Tax developments concerning financial institutions (April 2021)

1 Apr - Netherlands: Proposed changes to legal forms, possible tax implications

1 Apr - Australia: Synthesised text of income tax treaty with Indonesia

1 Apr - Channel Islands: Updated FATCA guidance, invalid or missing U.S. TINs (Jersey)

1 Apr - United States: Reasonable cause, penalty for failure to remit sufficient advance sales tax payment (Massachusetts)

March 2021

31 Mar - OECD: First exchanges of “no or only nominal tax jurisdictions”

31 Mar - Mauritius: Country-by-country reporting deadline, extension to 20 April 2021

31 Mar - United States: IRS to recalculate taxes on 2020 unemployment benefits, and automatically to issue refunds

30 Mar - United States: APMA program, APA statistics for 2020

30 Mar - United States: USTR announces hearings, requests comments about investigations of digital services taxes (Austria, India, Italy, Spain, UK, Turkey)

30 Mar - Hungary: VAT base reduced by bad debts; five-year limitations period (CJEU judgment)

30 Mar - Italy: VAT online registration portal, reporting cross-border sales and transactions

29 Mar - Australia: R&D tax incentive (Full Federal Court)

29 Mar - EU: European Parliament ECON committee vote on digital economy resolution; reporting requirements for digital businesses (DAC7)

29 Mar - India: Tax treaty benefits not available to Dutch fiscally transparent entity

29 Mar - Kuwait: “No objection letters” regarding tax compliance of foreign lenders

29 Mar - Saudi Arabia: Consultation on e-invoicing proposal

29 Mar - UK: Proposed changes to hybrid mismatch rules

29 Mar - UK: Second consultation regarding uncertain tax treatments by large businesses

29 Mar - United States: Additional tax deadlines extended to 17 May

29 Mar - United States: Clothing designs and patterns not eligible research expenses (U.S. Tax Court)

29 Mar - United States: Receipt of dividends or interest from a related CFC (IRS practice unit)

29 Mar - United States: Maine (federal tax conformity); New Mexico (disposal services); Wyoming (sales tax, car services); Multiple states (COVID relief funds)

26 Mar – United States: Next steps in digital services tax investigations

26 Mar - United States: Italian company to pay $950,000 to settle violations of Iranian sanctions

26 Mar - France: Treatment of pharmaceutical company’s rebates for VAT purposes; refund opportunities

26 Mar - Germany: VAT treatment of license granted by underwriting agent to insurer and insurance mediation services (CJEU judgment)

26 Mar - Portugal: Tax on capital gains realized by non-resident on transfer of immovable property (CJEU judgment)

26 Mar - Serbia: Update on income tax treaties

26 Mar - Switzerland: Guidance on implementing FATCA agreement with United States

26 Mar - UK: “Tax Day” overview of consultations and reviews primarily focused on tax system modernisation

26 Mar - UK: “Tax Day” re-design of tax administration

26 Mar - UK: Updated country-by-country reporting schema

25 Mar - UK: Consultation on transfer pricing documentation requirements

24 Mar - Belgium: Overview of tax and transfer pricing audits of multinational entities

24 Mar - Russia: Updated CRS regulations

24 Mar - Spain: VAT treatment of intra-group services; possible implications of CJEU judgment

24 Mar - United States: One penalty (not multiple) applies for untimely filing of FBAR reporting multiple bank accounts (Ninth Circuit)

23 Mar - United States: Overview of section 965 “transition tax" (IRS practice unit)

22 Mar - United States: Arkansas (rental excise tax); New York (budget proposals); Oregon (nexus and telecommuting workers); Virginia (federal tax conformity)

22 Mar - Serbia: Arm’s length interest rates for 2021

22 Mar - Sweden: Interest deduction limitation rules, taxpayer’s claim allowed (Supreme Administrative Court)

22 Mar - Canada: Mandatory disclosure of information about certain transactions (Quebec)

22 Mar - China: Proposal for simplified process for unilateral APAs

22 Mar - EU: Summary of CJEU judgments, EC actions (March 2021)

22 Mar - Singapore: Tax treatment of termination payments made under separation agreement (High Court)

19 Mar - Nigeria: Preparation and filing of first CRS return for 2020

19 Mar - Poland: EU VAT Directive precludes Polish measures on period for deducting input tax (CJEU judgment)

18 Mar - Mongolia: First transfer pricing tax assessment

18 Mar - United States: IRS memo for TE/GE division; interim guidance on 9100 relief for exemption applications

17 Mar - United States: IRS to extend tax filing deadline to May 17

17 Mar - United States: Updated FAQs under FATCA regime; penalty relief for withholding agents

17 Mar - Canada: CRA report on MAP program and statistics for 2019

16 Mar - Hungary: Tax on advertisement upheld (CJEU judgment)

16 Mar - Luxembourg: Guidance on mutual agreement procedures

16 Mar - Poland: Tax on retail sector upheld (CJEU judgment)

16 Mar - Liechtenstein: Updated guidance on AEOI data transmissions

16 Mar - United States: Sale of a partnership interest (IRS practice unit)

15 Mar - United States: Alabama (composite returns); Massachusetts (pandemic telecommuting); Virginia (combined reporting); Mississippi, Oklahoma, West Virginia (tax reform)

15 Mar - United States: Company to pay $216,000 to settle violations of Iranian sanctions

15 Mar - United States: IRS addresses electronic filing of Form 990-T

15 Mar - United States: Tax Court holds microcaptive insurance company arrangement fails; accuracy-related penalties warranted

15 Mar - Cayman Islands: Updated FATCA and CRS guidance

15 Mar - Mexico: Registration reminder for foreign providers of digital services

15 Mar - Netherlands: Third amendment, bill on dividend withholding tax in cross-border reorganizations

12 Mar - Sweden: VAT on services provided by head office to fixed establishment involving VAT group (CJEU judgment)

11 Mar - Netherlands: Update about tax treaty negotiations with Russia

11 Mar - South Africa: Third-party data annual submissions for AEOI

11 Mar - South Africa: Transfer pricing implications of catch-up payments and retroactive adjustments

10 Mar - Italy: Extended deadlines for digital services tax

10 Mar - OECD: Toolkit on tax treaty negotiations, for use by developing countries

10 Mar - United States: Guidance on digital products and streaming tax; SaaS determined to be taxable (Maryland)

9 Mar - Australia: FATCA reporting deadline extended; U.S. TIN information mandatory for 2020 reporting year

9 Mar - Austria: Technical guidance on changes to CRS XML schema

8 Mar - Netherlands: Mismatches in non-arm’s length transfer pricing, consultation on proposal

8 Mar - United States: Alabama (city use tax); Connecticut (taxation of remote work); Multistate (federal tax conformity)

8 Mar - EU: Negotiations with United States concluded to adjust agricultural quotas

5 Mar - EU: Negotiating positions of EU Council and European Parliament, proposal for “public” country-by-country reporting

5 Mar - Channel Islands: FATCA guidance related to missing U.S. TINs (Jersey)

5 Mar - Channel Islands: FATCA and CRS reporting guidance, compliance statement assurance (Guernsey)

5 Mar - United States: European Union and United States to suspend tariffs, large civil aircraft disputes

4 Mar - Spain: Tax regime benefitting professional football clubs; rules on determining state aid (CJEU judgment)

4 Mar - Taiwan: Updated user guide, CRS portal

3 Mar - Germany: Transfer pricing documentation guidelines, cross-border transactions between related parties

3 Mar - OECD: Technical changes in CRS XML schema 2.0

3 Mar - United States: IRS memo for TE/GE examiners; interim guidance on “section 506 notifications”

2 Mar - United States: Interest rates, tax underpayments and overpayments (second quarter 2021)

2 Mar - United States: Updated FAQs for QI / WP / WT

1 Mar - United States: First formal communication of “initial determination” asserting civil fraud penalty lacked prior supervisory approval (U.S. Tax Court)

1 Mar - United States: Maine (sales tax, cell phones); Massachusetts (digital advertising): New York State (resale, sales tax); Tennessee (sales tax, professional dues); Wisconsin (dividends-received deduction)

1 Mar - United States: Test case concerning “first sale” valuation and non-market economies (U.S. trade court)

1 Mar - EU: Update on “public” country-by-country reporting proposal, following discussion by ministers

1 Mar - Germany: VAT on cross-border provisions of company vehicles to employees (CJEU judgment)

1 Mar - Oman: Tax treaty with Sri Lanka, entry into force

1 Mar - Qatar: Transfer pricing documentation guidelines

February 2021

26 Feb - France: Updated FATCA technical guidance

26 Feb - OECD: United States drops “safe harbor” request on proposed digital tax rules

25 Feb - Liechtenstein: Updated FATCA technical guidance for missing TIN

25 Feb - Panama: Guidance for issuing electronic tax receipts and invoices

25 Feb - United States: CRS report on U.S. measures to address Huawei-related issues

25 Feb - United States: IRS focus on improper refund claims relating to domestic production activities deduction

25 Feb - United States: Section 263A computation for producers

24 Feb - United States: Credit card “reward dollars” held taxable income (U.S. Tax Court)

23 Feb - EU: Summary of tax developments including referrals to CJEU, state aid, local law and regulations (February 2021)

23 Feb - Switzerland: Court decision restricts application of U.S. tax treaty on basis of citizenship

23 Feb - Germany: Updated CRS guidance

23 Feb - Malaysia: Update, taxation of digital services by foreign service providers

22 Feb - Argentina: Tax benefits under regime to promote digital “knowledge” economy

22 Feb - Colombia: Tax calendar for 2021

22 Feb - EU: Status of proposal for public country-by-country reporting

22 Feb - EU: Updated “blacklist” of non-cooperative jurisdictions (Dominica added); revisions to “grey list”

22 Feb - Japan: Extended due date for individual income tax returns, payments

22 Feb - Switzerland: Updated CRS technical guidance

22 Feb - United States: Illinois (proposed corporate tax measures); New York State (sales tax, assets acquired under purchase agreement); Pennsylvania (retailer voluntary compliance); Utah (GILTI and FDII)

19 Feb - France: Updated CRS technical guidance

18 Feb - United States: Company to pay $507,000 to settle violations of multiple sanctions programs

17 Feb - Argentina: Exchanges of country-by-country reports, agreement with United States

17 Feb - Korea: Transfer pricing-related amendments in tax legislation

17 Feb - Liechtenstein: Updated CRS technical guidance

17 Feb - South Africa: Transfer pricing adjustment upheld; no transfer pricing documentation

16 Feb - North Macedonia: Disclosure requirements, ultimate beneficial owners

16 Feb - Australia: Objections on hold as tax authority appeals JobKeeper case

16 Feb - Dominican Republic: Tax amnesty, 90-day extension for applications by taxpayers

16 Feb - France: Taxpayer-favorable court decisions, administrative guidance on intragroup financial transactions

15 Feb - Costa Rica: Relief from certain information reporting on form D151

15 Feb - Germany: Updated CRS guidance for financial institutions

15 Feb - UK: Definition of “structure” for capital allowances purposes (Court of Appeal decision)

15 Feb - United States: Alabama (corporate tax); Louisiana (franchise tax); Maryland (taxation of digital products); New York (rental equipment, sales tax)

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

12 Feb - Mauritius: Protocol amending tax treaty with Eswatini (Swaziland)

12 Feb - Australia: ATO focus on cross-border financing arrangements

11 Feb - Canada: APA cost-recovery charges cancelled

11 Feb - Germany: Proposed revisions to transfer pricing rules

11 Feb - Malta: Updated FATCA, CRS guidelines on AEOI

11 Feb - United States: Research tax credit disallowed (U.S. Tax Court)

10 Feb - United States: Last in-first out (LIFO) records (IRS practice unit)

10 Feb - EU: Summary of EU tax developments concerns state aid, EU institutions, and local law and regulations (February 2021)

10 Feb - Rwanda: Transfer pricing rules

9 Feb - Czech Republic: Evidence establishing a foreign entity’s permanent establishment (court decision)

9 Feb - Serbia: Income tax treaties, as of 1 January 2021

9 Feb - Nigeria: Investment tax credit, production-sharing contracts and oil prospecting license (appeals court decision)

9 Feb - United States: Fees paid by U.S. company to German parent company under sourcing-assistance agreement not dutiable

8 Feb - United States: California (medical ultrasound services); Illinois (marketplace facilitators); Oregon (Portland “homeless” tax); Multistate (CEO compensation, excise tax proposals)

8 Feb - United States: IRS TE/GE division releases summary of “FY 2020 accomplishments”

5 Feb - United States: Trade court finds tariffs on steel imports did not violate Section 232

5 Feb - Cambodia: System for e-filing income tax returns; tax relief

5 Feb - Singapore: CRS registration deadline is 31 March 2021

4 Feb - Australia: ATO guidance, presence of employees not creating permanent establishment

4 Feb - Croatia: Arm’s length interest rate on loans between related parties for 2021

4 Feb - Hong Kong: Updated FAQs concerning AEOI and CRS regime

4 Feb - Norway: New VAT return, electronic filing expected in 2022

3 Feb - Belgium: Summary of recent tax developments including UBO register, proposed tax on securities accounts, court decisions

3 Feb - Channel Islands: Updated FATCA, CRS guidance (Jersey)

3 Feb - Germany: Updated FATCA guidance

3 Feb - Malaysia: Taxpayers now have 14 days to submit transfer pricing documentation when requested by tax authority

3 Feb - United States: University agrees to pay $54,000 to settle violations of Export Administration Regulations

3 Feb - Mexico: Disclosure of “reportable schemes” and 15 February 2021 deadline

2 Feb - Mexico: Foreign trade and AEO program changes, compliance rules for maquiladoras

2 Feb - Bahrain: Tax treaty with Switzerland, other tax developments

2 Feb - Oman: VAT registration via online portal, open 1 February 2021

2 Feb - Channel Islands: Changes to reporting system for FATCA and CRS (Guernsey)

2 Feb - India: Transfer pricing measures in Union Budget 2021-2022

2 Feb - Qatar: Transfer pricing declarations required via tax administration portal (Dhareeba)

1 Feb - EU: Summary of EU tax developments including CJEU judgments, EC infringement proceedings and referrals  (January 2021)

1 Feb - United States: IRS adds two compliance campaigns (LB&I division)

January 2021

29 Jan - Australia: Compliance implications, “significant global entity” and “country-by-country reporting entity”

29 Jan - Canada: XML schema updated again, FATCA and CRS information returns in 2021

29 Jan - EU: Extension of DAC 6 reporting deadlines announced by Belgium, Greece, Sweden

29 Jan - Saint Kitts and Nevis: Amendments to CRS regulations

29 Jan - Serbia: Guidance clarifying issuance of electronic invoices (e-invoices)

29 Jan - UAE: Suspension of customs declarations expires 31 January 2021

29 Jan - UK: Protocol signed, income tax treaty with Germany

29 Jan - UK: R&D tax relief claims, implications for SMEs (First-tier Tribunal judgment)

29 Jan - United States: Challenge to Section 232 steel “derivatives” tariff by importer of steel nails (U.S. trade court)

29 Jan - United States: IRS provides recordkeeping relief; increased deduction limits for corporate cash contributions for disaster relief

29 Jan - United States: TTB reminder, federal excise tax return filing dates for 2021

28 Jan - Israel: Characterization of intragroup recharges for stock-based compensation

27 Jan - Cayman Islands: Deadline for 2019 CRS compliance form extended to 15 September 2021

27 Jan - France: New tax compliance audit process; increased tax certainty for taxpayers

27 Jan - Kenya: Digital services tax, first return and payment expected in February 2021

27 Jan - Luxembourg: Updated zero-reporting guidance, FATCA and CRS

27 Jan - Switzerland: Guidance related to AEOI in tax matters

27 Jan - United States: Company to pay $540,000 to settle violations, telecommunications equipment destined for Russia

26 Jan - India: Intersection of claims for foreign tax credit and tax treaties

26 Jan - Japan: Proposed amendments to electronic tax records preservation system

26 Jan - Thailand: Guidance implementing rules for transfer pricing and related-party transactions

26 Jan - Bulgaria: Relief from certain anti-money laundering requirements for wholesale traders

25 Jan - Canada: Updated XML schema, FATCA and CRS information returns in 2021

25 Jan - EU: Resolution of European Parliament, reforming EU list of non-cooperative jurisdictions (“blacklist”)

25 Jan - Gibraltar: Update on application of EU mandatory disclosure rules (DAC 6)

25 Jan - India: Updated user guides under FATCA, CRS regimes

25 Jan - Saudi Arabia: Penalty waiver extended for late-filed tax returns, late tax payments

25 Jan - United States: Early distribution 10% extraction is a tax, not a penalty requiring written supervisory approval (U.S. Tax Court) 

25 Jan - United States: IRS establishes contact-free signature options for power of attorney, authorization forms

22 Jan - Luxembourg: Draft legislation to extend tax return deadlines

22 Jan - Hong Kong: Amendments to CRS provisions

21 Jan - Belarus: Proposed amendments to transfer pricing control provisions

21 Jan - Nigeria: Updated company registration portal

21 Jan - OECD: Updated guidance on tax treaties

21 Jan - Slovenia: Synthesized text of tax treaty with Qatar

21 Jan - Switzerland: Updated AEOI guidance under CRS regime

21 Jan - Switzerland: VAT returns require electronic filing beginning 2021, new e-filing platform

21 Jan - United States: Deductions and credits disallowed, foreign corporation did not file tax returns until after notice of deficiency (U.S. Tax Court)

20 Jan - United States: Penalty relief for partnerships, information reporting of partners’ beginning capital account balances for 2020

20 Jan - Sweden: Interest deduction limitation rules found in breach of EU law (CJEU judgment)

20 Jan - UAE: Additional time to comply with economic substance reporting

20 Jan - UK: Significant reduction in scope of UK implementation of DAC 6

19 Jan - Cambodia: Income tax treaty with Malaysia

19 Jan - EU: Taxation of digital economy, public consultation launched

19 Jan - Italy: Implementing decree for digital services tax; new deadlines

19 Jan - Netherlands: New policy statement on VAT fixed establishments

19 Jan - OECD: Toolkit for developing countries, transfer pricing documentation rules

19 Jan - United States: Employee payroll tax deferral, further postponed

19 Jan - United States: Information returns and payee statements waived regarding PPP, other relief programs

19 Jan - United States: Relief from addition to tax, underpayment of individuals’ estimated income tax

19 Jan - United States: Alaska (refund claim); Minnesota (audit notice delivery); New Jersey (combined group); Tennessee (marketplace facilitator)

15 Jan - Hungary: VAT reporting under electronic system, EKAER and real-time reporting

15 Jan - Italy: Deadlines for digital services tax extended

14 Jan - EU: Brexit implications for application of EU mandatory disclosures rules

14 Jan - Italy: Reduction in excise tax on fuel in northeast region (CJEU judgment)

14 Jan - Russia: First bilateral APA is concluded

14 Jan - Switzerland: Interest relief for late payments of tax has ended

14 Jan - UAE: Temporary VAT rate of 0% for medical equipment

14 Jan - United States: Findings from investigations of digital services taxes in Austria, Spain, United Kingdom

14 Jan - United States: Final regulations on denial of deductions for fines, penalties (released to Federal Register)

14 Jan - United States: Indonesian company to pay $1 million to settle violations of North Korea sanctions regulations

13 Jan - Bahrain: User fees for tax certificates, tax appeals

13 Jan - Belgium: Transfer pricing audits, new round of information requests

13 Jan - Brazil: Updated FATCA and CRS guidance

13 Jan - OECD: Compendium of comments on 2020 review of BEPS Action 14

13 Jan - Taiwan: Updated CRS guidance

12 Jan - Canada: Updated FATCA and CRS self-certification forms

12 Jan - Hong Kong: Updated AEOI guidance

12 Jan - India: Services not taxable under treaty with Sweden; technical explanation of U.S. tax treaty not binding

12 Jan - United States: Denial of deductions for fines, penalties (text of final regulations)

11 Jan - United States: Final regulations on denial of deductions for fines, penalties; OIRA review completed

11 Jan - United States: NOL limitation violates state’s Uniformity Clause; possible refund opportunities (Delaware)

8 Jan - United States: Section 4611(b) excise tax on domestic crude oil exports violates Export Clause (federal district court)

8 Jan - Panama: Tax payment due date extended to 15 January 2021

8 Jan - Albania: New e-invoicing rules, procedures

8 Jan - EU: Trade and cooperation agreement with UK

8 Jan - Japan: Updated FAQ under CRS regime, AEOI reporting system

8 Jan - KPMG report: Comments on OECD’s 2020 review of BEPS Action 14

8 Jan - Hong Kong: Proposed changes to tax treatment of amalgamations and filing of returns

8 Jan - Poland: Revised jurisdiction of tax authorities over business taxpayers

7 Jan - United States: Additional customs duties on imports from France suspended, digital services tax investigation

7 Jan - United States: Findings from investigations of digital services taxes in India, Italy, Turkey

6 Jan - United States: Tax policy implications of possible Democratic Senate

6 Jan - Finland: Updated CRS technical guidance

6 Jan - Hungary: Updated FATCA and CRS filing instructions

6 Jan - Liechtenstein: Amendments to regulations related to FATCA and CRS regimes

5 Jan - Germany: Transition to new CRS schema

5 Jan - Malaysia: Transfer pricing measures enacted

5 Jan - OECD: Consultation meeting on Pillar One and Pillar Two “Blueprints” scheduled for 14-15 January 2021

5 Jan - Qatar: Review tax liabilities on tax administration portal (Dhareeba) before 14 January 2021

5 Jan - United States: Additional U.S. customs duties effective 6 January 2021; response to French digital services tax

5 Jan - United States: IRS releases annual revenue procedures for 2021

5 Jan - United States: New TE/GE compliance initiatives

5 Jan - United States: Process for appealing adverse bond determinations, arbitrage rebate claim denials

4 Jan - Ghana: Changes to tax procedural and appellate processes

2020 Articles

December 2020

31 Dec - United States: Modified tariffs on EU products, response to large civil aircraft dispute

30 Dec - Serbia: Tax procedure and administration, new measures enacted

23 Dec - Germany: Updated FATCA guidance

23 Dec - Italy: Budget bill includes proposed APA rollback mechanism, APA application fees

23 Dec - KPMG report: OECD guidance on the transfer pricing implications of the COVID-19 pandemic

23 Dec - Panama: Multinational company headquarters, reporting requirements due 31 December 2020

23 Dec - Poland: Payments to employees for remote work-related internet, electricity not taxable income

23 Dec - Turkey: Country-by-country reporting, automatic exchanges under CbC MCAA

22 Dec - Italy: Regulations implementing tax dispute resolution mechanisms and MAP processes

22 Dec - Japan: Updated FAQs and relief regarding tax returns and tax payments

22 Dec - Luxembourg: Extended time to file corporate and individual tax returns for 2019 and 2020

22 Dec - Turkey: Extension of deadline for filing country-by-country report for 2019

21 Dec - Kazakhstan: Tax measures clarifying taxation of nonresidents, tax-free corporate transfers, application of treaty benefits

21 Dec - United States: Determining liability allocations; recourse vs. nonrecourse liabilities (IRS practice units)

18 Dec - France: Revised approach to determining permanent establishment; income tax and VAT consequences (Conseil d’Etat decision)

18 Dec - Italy: Measures to implement EU directive on cross-border arrangements (DAC 6)

18 Dec - Kenya: Digital services tax regulations provide details; scheduled effective date of 2021

18 Dec - Malaysia: Transfer pricing FAQs

18 Dec - OECD: Guidance on transfer pricing implications of COVID-19 pandemic

17 Dec - OECD: Compendium of comments on “Blueprints” concerning tax challenges from digitalisation of the economy

17 Dec - Australia: Transfer pricing recordkeeping options

17 Dec - Bulgaria: Tax administrative measures, VAT amendments effective 1 January 2021

17 Dec - Finland: Updated FATCA and CRS technical guidance

17 Dec - Germany: Supply of heat to property owners is subject to VAT (CJEU judgment)

17 Dec - Ireland: Updated CRS filing guidelines, XML schema

17 Dec - Italy: Draft decree to implement digital services tax, consultation open through 31 December

17 Dec - KPMG report: Country-by-country reporting; overview of notification requirements per country

17 Dec - Peru: Guidance for filing country-by-country reports for 2017, 2018 and 2019

17 Dec - United States: IRS memorandum for TE/GE employees, examination timelines again modified

16 Dec - Canada: Reminder of deadline for refund claims, pension plan contributions and employer insurance premiums

16 Dec - Hong Kong: Guidance on tax concessions and incentives for ship leasing operations

16 Dec - Netherlands: Upper House passes 2021 “tax plan” and other tax measures

16 Dec - OECD: Transfer pricing rules and implementation of hard-to-value-intangibles approach

16 Dec - Russia: Changes to APA process and measures related to controlled transactions

16 Dec - United States: Delayed e-filing requirements, Form 4720 filed by private foundations

15 Dec - United States: Denial of deduction for fines, penalties (final regulations pending OIRA review)

15 Dec - Canada: Expanded foreign affiliate reporting by resident multinational corporations

15 Dec - India: Subsidiary of a foreign company constitutes permanent establishment; gifting of shares

15 Dec - OECD: Transparency on tax rulings, status of spontaneous exchanges of information

15 Dec - Spain: Proposals for regulations to implement the digital services tax

14 Dec - Austria: Summary of tax developments (December 2020)

14 Dec - Bulgaria: New deadline for transfer pricing documentation

14 Dec - KPMG report: Comments concerning OECD “Blueprints” and tax challenges from digitalisation of the economy

14 Dec - Switzerland: Changes to AEOI provisions effective 1 January 2021

14 Dec - Switzerland: First group requests by IRS from Swiss financial institutions

14 Dec - UK: HMRC position on late-filing penalties for corporation tax returns; reasonable excuse for late filings

14 Dec - UK: MAP requests under EU Arbitration Convention no longer accepted after 2020, possible treaty implications

14 Dec - United States: Arizona (transaction privilege tax, license renewals); California (property tax, transfers between legal entities); Indiana (software, sales tax); New York (taxable storage services)

11 Dec - Bulgaria: New deadlines for filing corporate income tax returns and for paying tax

11 Dec - Netherlands: Rules for refunds of Dutch dividend withholding tax based on CJEU judgment

11 Dec - United States: Deadline extended, again, for individuals with signature authority (FBAR filings)

11 Dec - United States: Senate passes defense bill with anti-money laundering disclosure provisions

11 Dec - Cambodia: Change to e-VAT refund system, effective 2021

10 Dec - Australia: Updated ATO guidance, cross-border related-party financing arrangements

10 Dec - Bahrain: VAT relief for construction and real estate sector

10 Dec - Ireland: Updated filing guidelines for FATCA

10 Dec - UK: Statement on large civil aircraft dispute, USTR response

10 Dec - Vietnam: Guidance on VAT, mandatory e-invoicing delayed to 1 July 2022

10 Dec - Vietnam: Transfer pricing rules are updated

10 Dec - Vietnam: Various decrees on corporate and individual income tax, foreign contractor tax, tax administration

9 Dec - Belgium: Pending tax legislation, earnings stripping rules and implementing non-cooperative jurisdictions list

9 Dec - Netherlands: VAT exemption for collective asset management, possible refund opportunities (Supreme Court decision)

8 Dec - Netherlands: Tax developments concerning financial institutions (December 2020)

8 Dec - Sweden: New rules for permanent establishment determinations, tax withholding when work performed in Sweden

8 Dec - United States: Responsible officer certifications due by 15 December 2020

7 Dec - EU: Sint Maarten satisfied pre-requisites for application of registered export (REX) system

7 Dec - Liechtenstein: Updated FATCA and AEOI guidance

7 Dec - Nigeria: Relief from interest and penalties on outstanding taxes

7 Dec - Russia: Interest rates on controlled debt obligations, transfer pricing analysis not always required

7 Dec - Saudi Arabia: Regulations on e-invoicing and VAT

7 Dec - United States: Arizona (individual income surtax); Chicago (cloud services and computer software); West Virginia (sales tax exemption, equipment); Multistate (internet sales)

4 Dec - EU: Summary of EU tax developments including CJEU judgments, Advocate General opinion, referrals; EC developments (November 2020)

4 Dec - Malaysia: Transfer pricing measures included in Finance Bill 2020

4 Dec - Malta: CRS XML schema version change 10 January 2021

4 Dec - Peru: Country-by-country reports due 29 January 2021

4 Dec - Portugal: EC finds tax benefits in Madeira free zone not correctly applied

4 Dec - United States: Modified simplified production method; costs for UNICAP purposes

3 Dec - Australia: Updated guidance on APAs

3 Dec - Belgium: Tax rulings, downward adjustments to profits constituting “aid scheme” (CJEU Advocate General’s opinion)

3 Dec - Denmark: New requirement for annual submission of transfer pricing documentation

3 Dec - Isle of Man: Updated FATCA and CRS guidance

3 Dec - Nigeria: Six-year limitations period applies for tax audits, absent fraud or willful default or neglect

3 Dec - Poland: Partnerships to pay corporate income tax beginning in 2021

3 Dec - Turkey: Deadline for filing country-by-country report (2019) is 31 December 2020

3 Dec - United States: Employers must file Forms W-2, other wage statements and provide Forms 1099-NEC by 1 February 2021

3 Dec - United States: Interest rates, tax overpayments and underpayments (first quarter 2021)

2 Dec - EU: ECOFIN agreement on reporting requirements for digital businesses (DAC7), views on international issues including the digital economy

2 Dec - France: Requirements for mandatory e-invoices beginning 2023

2 Dec - Ghana: Transfer pricing regulations (2020)

2 Dec - Netherlands: FATCA issues encountered by Dutch citizens who are “accidental Americans”

2 Dec - United States: IRS to conceal sensitive taxpayer data on business tax transcripts

1 Dec - Australia: Due date for country-by-country reports deferred to 29 January 2021

1 Dec - Australia: Updated FATCA, CRS guidance

1 Dec - EU: Tax transparency rules to be extended to digital platforms

1 Dec - Finland: Updated versions of FATCA and CRS technical guidance

1 Dec - OECD: Toolkit for implementation of AEOI standard

1 Dec - Russia: Updated taxpayer information requirements, XSD schema for CRS reports

1 Dec - Saudi Arabia: Deadline of 31 December 2020 for waiver of penalties for tax return filings, payments 

1 Dec - UAE: Dubai Customs offers 80% discount on customs penalties

November 2020

30 Nov - Belgium: Treatment of dividends of French origin

30 Nov - Mexico: Disclosure of reportable tax schemes

30 Nov - New Zealand: Inland Revenue enforces the residential “bright-line test”

30 Nov - UK: Transfer pricing remains a significant focus for HMRC

30 Nov - United States: IRS partnership enforcement ramps up

30 Nov - United States: Updated public key for FATCA filings

27 Nov - France: Input VAT deductions, services provided by head office to branches (Conseil d’Etat decision)

27 Nov - Italy: Transfer pricing documentation guidelines (2020), replaces guidelines from 2010

27 Nov - Poland-Netherlands: Protocol to amend income tax treaty is signed

25 Nov - Australia: Robust comparables, practical considerations on managing the pricing of cross-border arrangements

25 Nov - Belgium: DAC6 and process for mandatory disclosure, reporting of cross-border arrangements

25 Nov - Malaysia: Tax audit framework for finance and insurance

25 Nov - Qatar: Mandatory “contract reporting” in new tax administration portal (Dhareeba)

23 Nov - Germany: New position on tax liability, IP structures without obvious nexus

23 Nov - Germany: Treatment of profit-transfer agreement in event of insolvency

23 Nov - OECD: Report on harmful tax practices, 18 jurisdictions in compliance with BEPS Action 5

23 Nov - United States: California (wireless service); Massachusetts (sales tax remittances); Massachusetts (non-resident S corporation); Nebraska (GILTI and FDII)

20 Nov - United States: Special enforcement matters, centralized partnership audit regime

20 Nov - Mexico-United States: Agreement on transfer pricing, tax treatment of maquiladoras

19 Nov - Switzerland: Amendments related to AEOI in tax matters

19 Nov - United States: IRS Priority Guidance Plan for 2020-2021

18 Nov - Cayman Islands: Updated CRS guidance

18 Nov - OECD: Report of MAP statistics for 2019

18 Nov - United States: Transfer pricing adjustments, deficiencies upheld (U.S. Tax Court opinion)

18 Nov - KPMG report: Initial impressions of RCEP free trade agreement

17 Nov - Luxembourg: Protocol amending income tax treaty with Russia is signed

17 Nov - South Africa: Actions required after changes to SARS transfer pricing e-filing system

17 Nov - Thailand: New transfer pricing regulation

17 Nov - United States: Final rule amending EAR, export enforcement provisions

16 Nov - EU: New system for reporting market-access barriers, trade agreement breaches

16 Nov - Indo-Pacific countries sign free trade agreement

13 Nov - Canada: Rates of interest for tax underpayments and overpayments, pension plan contribution limits

13 Nov - KPMG report: Year-end transfer pricing considerations

13 Nov - Belgium: Corporate tax return filing deadline is again extended

13 Nov - Mauritius: Tax relief allows deferral of tax payments

12 Nov - Bermuda: Updated user guide, CRS information reporting portal

12 Nov - Netherlands: Updated FATCA and CRS guidance

12 Nov - South Africa: Clarification of AEOI implementation

12 Nov - South Africa: Discussion paper on APAs

12 Nov - Spain: Details of digital services tax

12 Nov - Zambia: Supreme Court upholds transfer pricing adjustment of mining company

11 Nov - Poland: Legislative measures implementing EU VAT directives for e-commerce transactions

11 Nov - Australia: Transfer pricing arrangements and JobKeeper payments, updated guidance

10 Nov - Australia: Minor updates to ATO guidance on arm's length debt test

10 Nov - United States: QI / WP / WT application deadline, 24 November 2020

9 Nov - Argentina: Information reporting by multinational entities, new regime for reporting tax planning

9 Nov - China: Annual advance pricing arrangement (APA) report; statistics for 2019 and future considerations

9 Nov - EU: Agreement on dual-use goods and technologies

9 Nov - EU: Countermeasures against United States in large civilian aircraft dispute

9 Nov - Mexico: Taxation of digital services, enactment expected for January 2021 effective date

9 Nov - Nigeria: Penalty and interest relief available to 31 December 2020

6 Nov - Dominican Republic: Tax amnesty available until early January 2021

6 Nov - Japan: Updated FAQs on CRS regime

6 Nov - Lithuania: Updated transfer pricing documentation requirements

6 Nov - Netherlands: Update on tax treaty negotiations with Russia

6 Nov - Panama: MLI to enter into force March 2021

5 Nov - Germany: Updated CRS guidance for financial institutions

5 Nov - United States: IRS updates FAQs for QI / WP / WT

5 Nov - United States: IRS TE/GE compliance priorities, 2021 program letter

5 Nov - Australia: Ordinary income and the arm’s length value of “uneconomic assets” (Full Federal Court decision)

4 Nov - Cayman Islands: FATCA, CRS reporting extension to 16 December 2020

3 Nov - Slovakia: Right to input VAT deduction by importer (CJEU judgment)

October 2020

30 Oct - Australia: R&D tax benefits “reloaded”

30 Oct - EU: Tax issues in Belgium, Greece, Netherlands and Poland referred to CJEU

30 Oct - Liechtenstein: Updated CRS guidance, XML schema

30 Oct - Portugal: Requirement that tax documents contain unique codes is postponed

30 Oct - Switzerland: Updated AEOI data transfer manual

29 Oct - Italy: Certain CRS reporting obligations, deadline of 30 October 2020

29 Oct - Lithuania: Change to VAT refund process effective 1 January 2021

29 Oct - OECD: New methodology for peer review of BEPS Action 13 country-by-country reporting

29 Oct - Poland: Legislative proposal to expand scope of transactions subject to transfer pricing rules

29 Oct - France: Withholding tax on capital gains of nonresident shareholders; refund opportunities (court decision)

28 Oct - EU: Summary of EU tax developments including Advocate General opinions, EC developments (October 2020)

28 Oct - Germany: Method for calculating tolls on trans-European road network (CJEU judgment)

28 Oct - Romania: Transfer pricing adjustment, interest rate on intercompany loans (CJEU judgment)

28 Oct - Spain: Use of cost-sharing agreements to recover input VAT

27 Oct - Finland: Updated FATCA and CRS technical guidance

27 Oct - Singapore: FAQs on transfer pricing implications of COVID-19

26 Oct - EU considers countermeasures against United States in large civilian aircraft dispute

26 Oct - Netherlands: Withholding tax on dividends paid to foreign investment funds (Dutch Supreme Court decision)

23 Oct - Panama: Reporting relief for companies registered in the Panama-Pacific Area

23 Oct - Canada: Updated CRA position on travel restrictions, relief for non-resident employers

23 Oct - GCC countries: Comparison of VAT regimes in Bahrain, Oman, Saudi Arabia, UAE

23 Oct - Qatar: New process for filing, paying withholding tax

23 Oct - UAE: Notifications, reports under economic substance regulations

22 Oct - Kazakhstan: Protocol to amend income tax treaty with Luxembourg

22 Oct - Mexico: Taxation of digital services, legislative update

22 Oct - South Africa: Updated CRS regulatory guidance

22 Oct - United States: Comments regarding Rev. Proc. 94-69 and disclosure of change in tax position by large corporate taxpayers after exam is opened

22 Oct - United States: IRS provides temporary procedures allowing fax of material advisor disclosure statement

21 Oct - Spain: Digital services tax finalized, effective in January 2021

21 Oct - Turkey:  MLI and tax treaty-related considerations for Turkish investors in the Netherlands

20 Oct - India: Income from distribution rights, TV channels not taxable as royalty under U.S. tax treaty

20 Oct - Nigeria: Tribunal holds commercial rent is subject to VAT; conflicting opinion

20 Oct - Poland: Expanded scope of VAT bad-debt relief (CJEU judgment)

20 Oct - Russia: Proposed changes to advance pricing agreement (APA) procedures

20 Oct - United States: U.S. holding company to pay $4 million to settle violations of Iranian sanction regulations

19 Oct - Canada: Updated XML schema, FATCA and CRS information returns for 2021

19 Oct - France: Digital services tax to be paid in December 2020

19 Oct - United States: FBAR filing extensions clarified; FBAR for 2019 deemed timely if filed by October 31, 2020

19 Oct - United States: IRS compliance campaign spotlights deduction of success-based fees

19 Oct - United States: Transfer of intangible assets by partners to partnerships intended to shift pre-contribution gain to foreign partners (IRS field advice memo)

16 Oct - Netherlands: Guidance on FATCA and CRS regimes

15 Oct - Barbados: Deadlines for 2019 FATCA, CRS returns further extended to 31 October (COVID-19)

15 Oct - Brazil: Transfer pricing considerations (COVID-19)

15 Oct - Hungary: Advertisement tax, no infringement of EU state aid rules (CJEU Advocate General’s opinion)

15 Oct - Luxembourg: DAC 6 reporting guidelines released

15 Oct - Netherlands: Tax administration responds to Parliament’s FATCA questions

15 Oct - Poland: Tax on retail sector, no infringement of EU state aid rules (CJEU Advocate General’s opinion)

15 Oct - Thailand: Penalty relief for transfer pricing disclosure forms, if e-filed by 30 December 2020

15 Oct - United States: Initial impressions of final regulations, withholding and reporting obligations on dispositions of certain partnership interests

14 Oct - Switzerland: Updated FATCA guidance; AEOI statistics for 2020

14 Oct - UAE: Beneficial ownership disclosure rules, increased transparency

13 Oct - WTO decision in large civilian aircraft dispute; EU countermeasures against United States 

13 Oct - Austria: Refund of withholding tax allowed Canadian pension fund; possible refund opportunities for non-EU entities

12 Oct - KPMG report: Summary and initial analysis of Pillar One Blueprint

12 Oct - KPMG report: Summary and initial analysis of Pillar Two Blueprint

12 Oct - OECD: Pillar One and Pillar Two “Blueprints” and tax challenges of digital economy (text of reports)

12 Oct - Belgium: Postponed due date for corporate income tax return is 16 November 2020

12 Oct - Czech Republic: Transfer prices incorrectly set by companies receiving investment incentives (court judgment)

12 Oct - Hungary: Revised anti-money laundering regulation

12 Oct - Romania: Referral to CJEU, concept of fixed establishment for VAT purposes

9 Oct - EU: Summary of EU tax developments including CJEU judgments, referrals, EC actions (September 2020)

9 Oct - United States: IRS Chief Counsel memo, fraud penalty in TEFRA syndicated conservation easement cases 

9 Oct - United States: Treasury, quarterly list of countries cooperating with international boycott (possible future change)

9 Oct - Czech Republic: Status of digital tax proposal

9 Oct - United States: LB&I Focus Guide for FY 2021

8 Oct - United States: FAQs to allow fax submission of paper copy of Form 8886 (reportable transaction disclosures)

8 Oct - United States: Procedures, relief relating to steel articles imported from Brazil (Section 232 action)

8 Oct - Bermuda: Information reporting portal for CRS data filings closed until 8 November

8 Oct - Bulgaria: Updated AEOI guidance

8 Oct - Hong Kong: AEOI portal updates

7 Oct - Oman: Removal from EU “blacklist” of non-cooperative jurisdictions

6 Oct - EU: Updated “blacklist” of non-cooperative jurisdictions (Anguilla and Barbados added; Cayman Islands and Oman removed)

6 Oct - Poland: Changes relating to transfer pricing in pending legislation

6 Oct - Switzerland: Transfer pricing opportunities flowing from tax reform incentive regimes

6 Oct - United States: FBAR filing deadline; relief for persons affected by recent natural disasters

6 Oct - United States: IRS expanded enforcement focus on abusive micro-captive insurance companies

6 Oct - United States: New IRS compliance campaign on nonresident alien rental income from U.S. property (LB&I division)

5 Oct - United States: Practical guide to tax credit ordering and usage rules

5 Oct - Saudi Arabia: Tax amnesty through 31 December 2020

5 Oct - Turkey: Update on status of country-by-country reporting exchange agreement

2 Oct - Japan: Revisions to Japanese group relief system, ministerial ordinances and cabinet orders

1 Oct - United States: Electronic filing of Form 1040-NR allowed in certain instances

1 Oct - United States: IRS expands enforcement focus on abusive micro-captive insurance schemes

1 Oct - United States: IRS practice unit, cost-sharing arrangements with stock-based compensation

1 Oct - United States: Ohio Supreme Court holds for taxpayer in CAT sourcing dispute

1 Oct - United States: Company to pay $5.86 million to settle Cuban sanction violations

1 Oct - Zambia: Transfer pricing measures included in 2021 budget

September 2020

30 Sep - Australia: ATO guideline on working-from-home expenses

30 Sep - EU: Review of the proposal for plastic tax, environmental-related measures

30 Sep - Hungary: Real-time invoice reporting of VAT; “grace period” until 31 March 2021

30 Sep - Nigeria: Delegated tax collection authority held unconstitutional (Federal High Court)

30 Sep - Oman: Update on proposed VAT measures

29 Sep - Costa Rica: Update on VAT and cross-border digital services

29 Sep - Croatia: Reminder of transfer pricing compliance requirements

29 Sep - India: Guidelines selecting returns for “complete scrutiny” for FY 2020-2021

29 Sep - Nigeria: FAQs under CRS-AEOI regime; reminder, extended deadline expires 30 September

29 Sep - Poland: Expectations for transfer pricing-related inspections by tax authorities

29 Sep - United States: IRS updates FATCA registration system

29 Sep - United States: New IRS compliance campaign on consolidated NOL carryovers (LB&I division)

28 Sep - EU: New customs action plan and FAQs

28 Sep - India: No permanent establishment found; minimum alternative tax on sale of asset

28 Sep - Netherlands: VAT exemption for asset management services (pending before Supreme Court)

28 Sep - Oman: AEOI measures, CRS guidance

25 Sep - Ireland: EC to appeal General Court’s judgment; tax rulings held not selective tax advantages, arm’s length principle

25 Sep - Brazil: Updated FATCA and CRS guidance

25 Sep - Poland: Tax rulings on car fringe benefits, 50% deductible costs related to royalties

25 Sep - Singapore: Updated FATCA guidance and FAQs

24 Sep - KPMG report: Managing transfer pricing and COVID-19 implications for financial service companies

24 Sep - Netherlands: FATCA issues encountered by Dutch citizens with U.S. nationality

24 Sep - OECD: Status report on country-by-country reporting

24 Sep - UAE: Updated CRS guidance

24 Sep - United States: Company to pay $473,000 to settle Iranian sanction violations by Finnish subsidiary

24 Sep - United States: TE/GE memo updates examination process

23 Sep - Cambodia: Delayed implementation of e-filing for monthly tax returns

23 Sep - Chile: Summary of tax developments (September 2020)

23 Sep - Ireland: Possible tax measures for 2021 budget

23 Sep - Oman: Enacted income tax measures include AEOI amendments, tax residency provisions

23 Sep - Spain: Tax treatment of finance lease agreements involving shipyards held state aid (EU General Court)

23 Sep - United States: Final regulations pending OIRA review, consolidated NOLs

23 Sep - Philippines: Proposed legislation for taxation of digital services

22 Sep - Qatar: Reminder, new tax system registration deadline is 30 September 2020

22 Sep - United States: Updated FAQs for QIs / WPs / WTs

21 Sep - Switzerland: Analyzing a cash pool from a transfer pricing perspective

21 Sep - Switzerland: Mandatory e-filing of VAT returns beginning in 2021

18 Sep - UK: Updated HMRC guidance on job retention scheme

18 Sep - United States: IRS provides FAQs on “Bridge phase” under Compliance Assurance Process (CAP)

17 Sep - Belgium: Transfer pricing compliance, Local file deadline extended to October 2020

17 Sep - Cayman Islands: FATCA, CRS amended legislation enacted

17 Sep - Germany: Updated CRS guidance for financial institutions

17 Sep - Ireland: Updates to DAC2 and CRS filing guidelines

17 Sep - U.S. company agrees to pay $894,000 to settle violations of Sudanese sanction regulations

17 Sep - United States: IRS adds four compliance campaigns (LB&I division)

17 Sep - Nigeria: Requirement for mandatory registration by taxpayers

16 Sep - Nigeria: Rental income not subject to VAT (tribunal decision)

16 Sep - UK: Businesses have 30 days to confirm job retention scheme claims

16 Sep - United States: IRS draft of Form 990-T for 2020 would revise reporting of UBTI

16 Sep - United States: IRS release on expedited request for letter rulings

16 Sep - United States: LB&I directive allows examiners to accept R&D expenses as reported on taxpayer financial statements

15 Sep - United States: Overview of dollar value LIFO (IRS practice unit)

14 Sep - United States: Biden’s tax proposals (FAQs, updated 14 September)

14 Sep - Ireland: Updated FAQs for CRS

14 Sep - Russia: AEOI guidance, insurers included in list of financial organizations

14 Sep - Saudi Arabia: Customs self-correction program ends 30 September 2020

14 Sep - Saudi Arabia: Tax declarations, payments due by 30 September 2020

11 Sep - Canada: Extended tax deadlines, may affect tax assessment periods

11 Sep - Korea: Amendments in pending legislation would revise APA, MAP rules

11 Sep - Mauritius: Tax measures in global business regime reforms, effective 1 July 2021

10 Sep - Australia: Tax authorities review disclosures of international dealings for hybrid arrangements

10 Sep - Bahrain: VAT assessment process and appeals procedures (FAQs)

10 Sep - Belgium: New CRS schema required beginning 8 January 2021

10 Sep - United States: IRS expands list of forms and returns available for digital signature

10 Sep - United States: Foreign-earned income exclusion, audit techniques (IRS practice unit)

9 Sep - Australia: ATO clarification of hybrid mismatch rules

9 Sep - China: Tax administration Q&As on permanent establishment and tax residence rules

9 Sep - Finland: Updated FAQs related to FATCA and CRS

9 Sep - Poland: Transfer pricing changes included in draft bill

9 Sep - United States: Medicaid coverage of COVID-19 testing and diagnostic services

9 Sep - United States: Timely e-filed return triggers limitations period, even when initially rejected by IRS (U.S. Tax Court)

8 Sep - Italy: Updated list of reportable jurisdictions for AEOI under CRS regime

8 Sep - Netherlands: Updated IGA with United States

8 Sep - Poland: Proposed changes to withholding tax on payments for foreign-provided intangible services

8 Sep - Russia-Cyprus: Protocol to income tax treaty

8 Sep - United States: Foreign insurance companies; effectively connected net investment income (2019)

8 Sep - United States: Regulations on business interest expense deduction limitations under section 163(j); effective date and reliance clarifications and changes

4 Sep - Greece: APA rollback rules are expanded

4 Sep - Portugal: Requesting withholding tax exemptions under income tax treaties, model forms

4 Sep - Netherlands: Employer reporting obligations, temporary employment of foreign workers

4 Sep - UK: Update from HMRC on “new normal”

3 Sep - Canada: Extended tax-residency and permanent establishment relief

3 Sep - Italy: Claims for VAT refunds do not require bank guarantees

3 Sep - Singapore: FATCA regulations effective 2021; FAQs on CRS regime

3 Sep - United States: Highlights of final BEAT regulations under section 59A

3 Sep - United States: Interest rates, tax overpayments and underpayments (fourth quarter 2020)

2 Sep - Chile: New transfer pricing reporting requirements, Master file and Local file

2 Sep - EU: Summary of EU tax developments including CJEU judgments, referrals, EC actions (August 2020)

2 Sep - Kenya: Income tax treaty with Mauritius, ratification process completed

2 Sep - United States: FAQs on North Carolina’s initiative for resolving transfer pricing issues

1 Sep - Belgium: Reminder of transfer pricing deadlines; reducing audit risk

1 Sep - Malaysia: Updated service tax policies reflect digital services tax measures

1 Sep - Russia: Updated list of financial market organizations for CRS purposes

1 Sep - United States: BEAT provisions under section 59A (text of final regulations)

1 Sep - United States: Future regulations to address QBAI for FDII, GILTI purposes and qualified investment property treatment

1 Sep - United States: IRS launches BBA centralized partnership audit regime webpage

1 Sep - United States: Settlement proceeds not return of capital, but taxable income (Eleventh Circuit)

August 2020

31 Aug - United States: IRS supervisory approval for penalty assessment (U.S. Tax Court)

31 Aug - United States: IRS provides tax relief to taxpayers affected by Hurricane Laura

31 Aug - United States: Tax relief, updated state and local tax guidance (updated 31 August)

31 Aug - United States: Cincinnati (consolidated returns); District of Columbia (opportunity zones); North Carolina (inter-company pricing initiative)

31 Aug - United States: Initial analysis of Notice 2020-65, guidance on employee payroll tax deferral

28 Aug - United States: Payments under wireless service agreements constitute rents from real property for REIT (PLR)

28 Aug - Australia: Updated FATCA guide for software developers

28 Aug - Brazil: FATCA and CRS reporting deadlines extended

28 Aug - EU: Retroactive intercompany transfer pricing adjustments and customs valuation of imported goods

28 Aug - Finland: Updated FATCA and CRS technical guidance

28 Aug - United States: IRS temporarily to allow digital signatures on certain forms and returns

27 Aug - Argentina: Electronic registration, VAT portal

27 Aug - Cambodia: Updated procedures for taxpayer registration

27 Aug - Canada: Extended late-filing penalty relief, extended HSF credit for employers (Quebec)

27 Aug - Canada: Four-week extension of relief program proposed for furloughed employees

27 Aug - Canada: Investors to share data with investment plans for GST/HST compliance

27 Aug - Luxembourg: Updated XSD schema, technical guidance under FATCA and CRS regimes

27 Aug - UAE: Updated CRS guidance, legislation and regulations

27 Aug - United States: IRS opens application period for 2021 Compliance Assurance Process (CAP) program

27 Aug - United States: Foreign-earned income for purposes of section 911 (IRS practice unit)

26 Aug - Australia: ATO focus on “offshore gearing” structures, related-party financing

26 Aug - Japan: Updated Q&As, group relief system under 2020 tax reform

26 Aug - UAE: Amendments to country-by-country reporting requirements

26 Aug - United States: Pre-TCJA section 199 deduction claimed for processed seismic data (U.S. Tax Court)

25 Aug - EU: “Rules of origin” to be updated for 20 trade agreements

25 Aug - Nigeria: Court rejects 25% limit on certain retirement payments

24 Aug - China: Temporary closure of AEOI portal for CRS reports

24 Aug - Italy: Recovery of late-charged input VAT following self-disclosure

24 Aug - Netherlands: Treatment of bonus shares under work-related costs rules

24 Aug - Singapore: Updated CRS XML schema instructions

24 Aug - Taiwan: Draft amendments to transfer pricing assessment rules

24 Aug - United States: IRS interim guidance on designation of cases for litigation

21 Aug - India: Guidance for mutual agreement procedure (MAP)

21 Aug - UK: Guidance on disguised remuneration and loan charge implementation

21 Aug - United States-Switzerland: Competent authority arrangement, implementing arbitration process and MAP process

21 Aug - United States: IRS statement on failure-to-deposit penalties, employers claiming new tax credits

20 Aug - Australia: Updated “software developer kit guide,” FATCA and CRS regimes

20 Aug - Italy: Decree published, FATCA and CRS reporting deadline extended to 30 September

20 Aug - Malaysia: Guide on taxation of digital services by foreign service providers

20 Aug - Pakistan: Proposals to implement CRS rules

19 Aug - Canada: Extended relief from interest, penalties for business taxes in Ontario

19 Aug - Romania: Employment-related relief measures

19 Aug - UK: HMRC “Q&As” on statutory residence test and displaced employees

19 Aug - KPMG report: Future of global tax disputes; tax authority reactions, guidance and expectations

19 Aug - United States: LIFO pooling requirements; distributions not from accumulated earnings and profits (IRS practice units)

18 Aug - Hungary: Tax legislative measures include DAC6 implementation, changes to local tax and VAT

18 Aug - Russia: Tax audit guidelines, verifying reasonableness of expenses for intra-group services

17 Aug - Singapore: Revised FATCA form released

17 Aug - United States: IRS makes electronic filing available for Form 1040-X

17 Aug - United States: Last round of ITINs expiring in 2020; renewal encouraged to prevent refund delays (IRS reminder)

14 Aug - United States: Section 986(c) gain or loss, pre-2017 tax law (TCJA) (IRS practice unit)

14 Aug - Bahrain: Requirements to file economic substance returns

14 Aug - Canada: Updated FATCA and CRS guidance

14 Aug - Czech Republic: Limitations period for tax inspections when tax loss reported (court decision)

14 Aug - EU: Financial services, tax update (August 2020)

14 Aug - Russia: Proposal to increase withholding tax rates under treaties

14 Aug - United States: IRS memorandum for TE/GE employees; church claims for refund or abatement

13 Aug - Australia: Guidance on interest-free loans between related parties; thin capitalisation arm’s length debt test

13 Aug - Czech Republic: Rate of interest payable to taxpayers on excess VAT

13 Aug - India: Due diligence procedures, determining “controlling person” under FATCA and CRS regimes

12 Aug - Philippines: Guidance on completing related-party transaction Form No. 1709

12 Aug - United States: Income from gravel mined on Indian tribal land, taxable (Second Circuit)

12 Aug - United States: Increased user fees for employee plan rulings and determinations

11 Aug - Myanmar: Tax audit processes outlined by tax authority

11 Aug - South Africa: Proposed anti-avoidance rules, preference share funding structures

10 Aug - Bulgaria: Deferred deadline for reportable cross-border tax arrangements (DAC6)

10 Aug - United States: Initial impressions about presidential memorandum on deferring payroll tax obligations

10 Aug - United States: IRS addresses settlement period for stock options

8 Aug - United States: Deferral of collection of payroll taxes (executive memorandum)

7 Aug - Italy: Mandatory disclosure directive (DAC6), transposition into domestic law

7 Aug - UK: Opportunity for refund, voluntary tax payments for certain employment-related loans

7 Aug - France: Annual transfer pricing return, filing deadline postponed

5 Aug - Ecuador: Transfer pricing methodology for banana exports; other transfer pricing reforms

5 Aug - Luxembourg: FATCA and CRS returns, filing date extended to 30 September

5 Aug - South Africa: Proposal would allow estimated assessment for certain taxpayer failures

4 Aug - United States: FAQs address PPP loan forgiveness issues

4 Aug - United States: Biden’s tax proposals (FAQs)

4 Aug - United States: Initial analysis of regulations, guidance under section 163(j)

3 Aug - Mexico: FATCA and CRS filing deadlines extended to 7 December 2020

3 Aug - Portugal: Mandatory disclosure reporting deadlines under DAC6 postponed

3 Aug - United States: Initiative for voluntary resolution of state-level transfer pricing issues (North Carolina)

July 2020

31 Jul - United States: IRS updates FAQs on deferral of employment tax deposits, payments

30 Jul - Brazil: Comments requested, transfer pricing issues relating to safe-harbour, comparability considerations

30 Jul - United States: IRS concept unit on accuracy-related penalties, tax professionals urge caution

29 Jul - Australia: Transfer pricing rules updated to align with OECD guidelines

29 Jul - Brazil: Proposal to replace PIS and COFINS with new federal VAT; would capture digital transactions

29 Jul - Italy: Updated, revised R&D tax credit system

29 Jul - OECD: Mutual administrative assistance in tax matters, toolkit for developing countries

29 Jul - United States: IRS’s temporary procedure for filing Form 3115, accounting method changes

29 Jul - United States: Receipts from related CFC; accuracy-related penalties (IRS practice units)

29 Jul - United States: Regulations under section 163(j): Calculating ATI for cooperatives

28 Jul - India: Treatment of web-related services, project office under tax treaties with United States and Korea

28 Jul - United States: Senate Republican proposals would limit withholding for remote workers, nexus for employers

27 Jul - Portugal: Reporting domestic or cross-border arrangements with tax relevance (DAC6)

27 Jul - Saudi Arabia: Tax ruling requests, updated guidelines

27 Jul - United States: Nevada (tax amnesty); Washington State (B&O tax, loans)

27 Jul - United States: Refundable employment tax credits; assessment for erroneous refundable credits

23 Jul - Canada: Updated XML schema under FATCA and CRS regimes

22 Jul - India: Seconded employee did not create permanent establishment under tax treaty with Singapore

22 Jul - United States: Court holds enforcement of unclaimed property subpoena would constitute abuse (Delaware)

21 Jul - Dominican Republic: Special tax regime to settle tax debts

21 Jul - Liechtenstein: Updated CRS schema; AEOI and FATCA revisions approved

21 Jul - Switzerland: Updated AEOI technical guidance

20 Jul - Canada: Updated post-filing instructions for FATCA, CRS returns

20 Jul - EU: More time for countries to comply with REX system, origin of goods certification

20 Jul - Korea: Amendments to FATCA and CRS regulations

20 Jul - United States: Addressing liquidity issues using intercompany pricing tools (COVID-19)

20 Jul - United States: Foreign tax credit limitation and computation (IRS practice unit)

20 Jul - United States: GILTI and subpart F high-tax exception (text of final and proposed regulations)

20 Jul - United States: Taxable REIT subsidiary found not operating a disqualifying healthcare facility (PLR)

17 Jul - Hong Kong: Guidance on APA procedures

15 Jul - Belgium: Proposal for digital services tax

15 Jul - EU: New tax package proposed; tax treatment of digital platforms addressed

15 Jul - Ireland: Tax rulings found not selective tax advantages; arm’s length principle (General Court of EU)

15 Jul - United States: IRS closures of several P.O. Box addresses for business tax payments including employment tax payments

15 Jul - United States: IRS notification regarding delay in processing advance payment of employer credits

15 Jul - United States: Presidential proclamation on tariffs on Turkish steel violated statute; refunds allowed (U.S. trade court)

14 Jul - Finland: Updated FATCA, CRS technical guidelines

14 Jul - India: Opportunity for taxpayers to validate electronically filed income tax returns

14 Jul - United States: French digital services tax; additional 25% customs duties suspended until January 2021

14 Jul - United States: IRS LB&I division releases practice units for IRS examiners

14 Jul- United States: Proposed changes to Form 1065 for partnerships with international tax items

13 Jul - Germany: List of countries for information exchanges under CRS regime

13 Jul - United States: Treatment of NOLs of unrelated trades or businesses (IRS Chief Counsel Advice)

10 Jul - Chile: MLI approved by Congress

10 Jul - UK: House of Commons passes digital services tax legislation

10 Jul - Belgium: Guidance on transfer pricing reporting, BEPS 13 forms

9 Jul - Argentina: Revised reporting dates for submitting transfer pricing reports for prior years

8 Jul - OECD: Corporate tax statistics from country-by-country reporting, activities of multinational enterprises

8 Jul - United States: Oregon’s taxation of railroad intangible property held discriminatory (Ninth Circuit)

8 Jul - Vietnam: Deadline for FATCA returns extended to 1 November 2020

7 Jul - Brazil: Proposed COFINS regime for digital sector taxpayers

7 Jul - Canada: Tax treaty with Madagascar, entry into force

7 Jul - Canada: Updated instructions for FATCA returns

7 Jul - Finland: VAT treatment of “co-location services” (CJEU judgment)

7 Jul - Germany: Deadlines for FATCA and CRS returns extended to 31 October 2020

7 Jul - Luxembourg: Filing deadlines for FATCA, CRS returns to be postponed

7 Jul - OECD: Global tax reporting framework for digital platforms

7 Jul - Sweden: New obligations for employers concerning foreign workers

7 Jul - United States: IRS memorandum for TE/GE employees, modified examination timelines

6 Jul - Cayman Islands: Bulk uploading of CRS compliance forms

6 Jul - Italy: FATCA and CRS reporting deadline extended to 30 September 2020

6 Jul - Japan: Updated FAQs on common reporting standard regime

6 Jul - Oman: Country-by-country reporting, transfer pricing guidelines anticipated

6 Jul - Poland: Postponed deadlines for transfer pricing documentation, reporting

6 Jul - UAE: Amendments to CRS rules, Abu Dhabi

6 Jul - UK: IT services provided single fund management service not exempt from VAT (CJEU judgment)

6 Jul - United States: IRS adds section 965 compliance campaign under TCJA (LB&I division)

6 Jul - United States: IRS practice unit: Reasonable cause and good faith

2 Jul - Qatar: Mandatory taxpayer registration, new tax administration portal (Dhareeba)

2 Jul - South Africa: Tax Ombud’s report on dispute resolution rules, procedures

2 Jul - United States: Jurisdiction for tax overpayment interest claims (Federal Circuit)

2 Jul - United States: LB&I memo on activities postponed, continued and resuming

1 Jul - Zambia-Mauritius: Tax treaty negotiations

June 2020

30 Jun - Canada: Extended tax residency and permanent establishment relief, travel restrictions

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

29 Jun - United States: National Taxpayer Advocate report to Congress identifying taxpayer challenges

29 Jun - United States: New FAQs on faxing refund claims, NOL carrybacks under CARES Act

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)

Tax Dispute Resolution Quarterly

The Summer 2021 edition of Tax Dispute Resolution Quarterly features articles on:

  • Remarkably unremarkable APA results
  • U.S. tax reform: BEAT down, SHIELD up
  • MAP, more MAP, and ICAP
  • Misalignment of CbC reporting and value
  • Transfer pricing takeaways from Coca-Cola case
  • Survey of global secondary adjustment rules.

Read the Summer 2021 Tax Dispute Resolution Quarterly

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