Autumn 2021

Main

Last stretch to taxing the digital economy

Brazilian tax group pushes for racial inclusion in the tax industry

US tax reform: Yes… No… Maybe

Accounting reform is the key to successful corporate tax agreements

Tax transparency increasingly crucial for attracting investment

Brazil’s move to adopt OECD TP guidelines could boost FDI

Brazil’s tax reform raises investment concerns over dividends

China’s bonded refurbishment policy seeks to ease pressures for medical device businesses

MNEs stand to gain greater tax certainty from joint audits

Taxpayers could turn to ADR over threat of post-COVID tax disputes

US tax regulation still too ambiguous on classifying crypto assets

Taxpayers weigh up the benefits and difficulties of remote working

Diversity in tax: A long way to go

APAC tax receipts to grow as countries target e-commerce activities

Tax incentives pave the way for India to become a global manufacturing hub

MNEs use shared service centres to bolster digitalisation projects

Pandemic caused TP challenges for businesses conducting comparability analysis

Multinational companies are looking to move their supply chains out of China

What should taxpayers do if DSTs are here to stay

Pandora Papers will increase scrutiny on MNE tax affairs

EU moves a step closer towards public CbCR

Businesses to face more pressure from HMRC over data access

Taxpayers lose at the Indian Supreme Court in litigation involving input tax credit refunds under GST

Cooperative compliance marks a ‘quiet revolution’

Tax Relief

Australia: Reform of employee share schemes – tax view

China: Enhances tax inspection procedures and builds new Hengqin-Macau cooperation zone

Chile: International teleworking and complying with tax obligations

France: Taxation of real estate capital gains and the questionable outcome of the French assimilation process

Germany: 2021 German Administrative Principles – impact on TP and intangible contributions

Greece: Start-up businesses have no tax and TP considerations or do they?

Hong Kong SAR: The impact of the OECD’s BEPS 2.0 proposals

India: Brings down the curtain on retrospective amendment to indirect transfer provisions

Indonesia: Law updated on bond-related investments and VAT for retail merchant tenants

Luxembourg: VAT digitalisation – harnessing technology to enhance VAT management

Netherlands: Concludes abuse of law and denies interest expenses in PE fund

New Zealand: New tax disclosure requirements for overseas investment

Norway: Supreme Court judgment on the interpretation of the ‘offshore’ clause and the taxation of employees

Poland: Changes ahead for tax legislation from 2022

State support measures aid investment projects in Russia

Singapore: Tax authorities issue revised TP guidelines

Sweden: The economic employer concept – how is it going?

Switzerland: Supreme Court restricts the application of the Swiss Old Reserves practice

Thailand: The move from LIBOR and TP – a Thai perspective

US: Tax Court finds limits to treaty-based double tax relief

Cover Story

Last stretch to taxing the digital economy

International Correspondents

Australia: Reform of employee share schemes – tax view

China: Enhances tax inspection procedures and builds new Hengqin-Macau cooperation zone

Chile: International teleworking and complying with tax obligations

France: Taxation of real estate capital gains and the questionable outcome of the French assimilation process

Germany: 2021 German Administrative Principles – impact on TP and intangible contributions

Greece: Start-up businesses have no tax and TP considerations or do they?

Hong Kong SAR: The impact of the OECD’s BEPS 2.0 proposals

India: Brings down the curtain on retrospective amendment to indirect transfer provisions

Indonesia: Law updated on bond-related investments and VAT for retail merchant tenants

Luxembourg: VAT digitalisation – harnessing technology to enhance VAT management

Netherlands: Concludes abuse of law and denies interest expenses in PE fund

New Zealand: New tax disclosure requirements for overseas investment

Norway: Supreme Court judgment on the interpretation of the ‘offshore’ clause and the taxation of employees

Poland: Changes ahead for tax legislation from 2022

State support measures aid investment projects in Russia

Singapore: Tax authorities issue revised TP guidelines

Sweden: The economic employer concept – how is it going?

Switzerland: Supreme Court restricts the application of the Swiss Old Reserves practice

Thailand: The move from LIBOR and TP – a Thai perspective

US: Tax Court finds limits to treaty-based double tax relief

Features

Brazilian tax group pushes for racial inclusion in the tax industry

US tax reform: Yes… No… Maybe

Accounting reform is the key to successful corporate tax agreements

Tax transparency increasingly crucial for attracting investment

Brazil’s move to adopt OECD TP guidelines could boost FDI

Brazil’s tax reform raises investment concerns over dividends

China’s bonded refurbishment policy seeks to ease pressures for medical device businesses

MNEs stand to gain greater tax certainty from joint audits

Taxpayers could turn to ADR over threat of post-COVID tax disputes

US tax regulation still too ambiguous on classifying crypto assets

Taxpayers weigh up the benefits and difficulties of remote working

Diversity in tax: A long way to go

APAC tax receipts to grow as countries target e-commerce activities

Tax incentives pave the way for India to become a global manufacturing hub

MNEs use shared service centres to bolster digitalisation projects

Pandemic caused TP challenges for businesses conducting comparability analysis

Multinational companies are looking to move their supply chains out of China

What should taxpayers do if DSTs are here to stay

Tax Relief

Tax Relief

Special Features

News Analysis

Pandora Papers will increase scrutiny on MNE tax affairs

EU moves a step closer towards public CbCR

Businesses to face more pressure from HMRC over data access

Taxpayers lose at the Indian Supreme Court in litigation involving input tax credit refunds under GST

Cooperative compliance marks a ‘quiet revolution’

Editorial

Sponsored

Sponsored

Sponsored by Dhruva Advisors

India: Brings down the curtain on retrospective amendment to indirect transfer provisions

Umesh Gala, Saurabh Shah and Rushi Shah of Dhruva Advisors explain the impact of withdrawal of indirect transfer provisions.

Rushi Shah, September 07, 2021
Sponsored by Crowe Singapore

Singapore: Tax authorities issue revised TP guidelines

Sivakumar Saravan and Sowmya Varadharajan of Crowe Singapore consider the most notable changes introduced in the 6th edition of the Singapore Transfer Pricing Guidelines.

Sivakumar Saravan, September 03, 2021
Sponsored by Deloitte Norway

Norway: Supreme Court judgment on the interpretation of the ‘offshore’ clause and the taxation of employees

Anette Fjeld and Lene Bergersen of Deloitte Norway explain the Norwegian Supreme Court judgment in the case between six sea workers and Poseidon Personnel Services SA on one side and the Norwegian state on the other side.

Anette Fjeld, September 03, 2021

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