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Tax Dispute Resolution

Tax Dispute Resolution

TaxNewsFlash-Tax Dispute Resolution — KPMG's reports of tax dispute resolution developments from around the globe involving income taxes, transfer pricing, indirect taxes, and other taxes

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Sharon Katz-Pearlman

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

KPMG International

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Recent Articles

May 2021

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

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 - 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

Recent Articles

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)

6 Dec - EU: Energy taxation, EU blacklist discussed at ECOFIN meeting

6 Dec - EU: Summary of CJEU actions, referrals, EC infringement actions, other tax developments (December 2019)

6 Dec - India: Application of MLI to tax treaties with Australia, Finland, Japan, Singapore, Slovakia, UAE

6 Dec - Italy: Financial transaction tax is challenged (CJEU Advocate General opinion)

6 Dec - Sweden: Mandatory reporting requirement rules, effective date July 2020

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

6 Dec -  United States: No change to interest rates on tax underpayments, overpayments (first quarter 2020)

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

4 Dec - Netherlands: Reduced transfer tax, office building converted into residential apartments

4 Dec - OECD responds to U.S. Treasury’s letter on digital services tax

4 Dec - United States: Treasury opposition to digital services tax initiatives, support for Pillar One

4 Dec - United States: Disregarded limited partnerships no longer subject to filing requirement or annual tax in California (possible refund opportunities)

3 Dec - Austria: Court addresses abusive assignment of receivables; brief descriptions of other tax developments

3 Dec - Belgium: Tax prepayments and effects of earnings stripping rules

2 Dec - United States: Conclusions, trade-related investigation of France’s digital services tax

Tax Dispute Resolution Quarterly

The Winter 2021 issue of Tax Dispute Resolution Quarterly features articles on how transfer pricing remains crucial as the IRS CAP program opens for 2021, digital services tax: why the world is watching, reflections on a very unusual year in SALT, and much more.

Read the Winter 2021 Tax Dispute Resolution Quarterly

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