October/November 2019

Main

How NGOs changed the global tax debate

Market insight

Tax transparency: Imperfect vision

Auditors rely on trust and verification methods

The B Team presents its business case for responsible tax

Beyond and beneath the arm’s-length principle

‘Ease of Doing Business’ Large taxpayer GST units necessary in India

Americas Tax Awards 2019: The winners

EU circular economy plans could cut tax costs for companies

Do new transparency obligations help us know our company better?

Taxpayers surprised by India’s corporate tax cuts

EU court rules in favour of Starbucks, but against Fiat over state aid

First filings under UK Making Tax Digital go ‘fairly smoothly’

Mexico’s VAT reforms risk foreign digital platforms exiting market

India GST Council’s tax tweaks welcomed

OECD MAP statistics offer mixed views on dispute resolution

HMRC delays ‘sledgehammer’ VAT reverse charge

Glencore wins TP dispute against Australian Taxation Office

Treading water

Tax Relief

Australia: Glencore triumphs over ATO in landmark Australian transfer pricing case

Brazilian tax authorities provide guidance on ‘debit to shareholders account’ transactions

Chile continues with the modernisation of its tax system

China: China introduces new free trade zones and improved practices

Colombia begins taxing indirect sales

Germany: How to adapt to the DEMPE concept when using third-party licensing agreements for transfer pricing

Greece: Analysing partial demergers

Hong Kong: IRD publishes long awaited practice notes on transfer pricing

India: Analysing foreign portfolio investor taxation in India

Indonesia: Indonesia issues a flurry of tax-related regulations

Israel: How the Israel tax authorities are interpreting intergroup intangibles exports

Italy: Italy issues guidelines on prevention of tax evasion

Luxembourg: Mandatory disclosure rules announced in Luxembourg

New Zealand: New Zealand government updates tax reform priorities

Poland: Poland introduces the white list of VAT taxpayers

Romania: The future of taxation in the digital era looks promising for Romania

Russia: Supreme Court issues decision on allocation of costs to income

South Africa: National Treasury releases proposed international tax amendments

Spain: Protocol of the Spain-US tax treaty enters into force

Switzerland: Swiss-US double tax treaty protocol enters into force

Thailand issues regulation on stamp duty payment for electronic documents

US inbound: IRS proposes new guidance for cloud transactions

US outbound: OECD statistics show continued effectiveness of MAP cases globally and in US

Cover Story

How NGOs changed the global tax debate

International Correspondents

Australia: Glencore triumphs over ATO in landmark Australian transfer pricing case

Brazilian tax authorities provide guidance on ‘debit to shareholders account’ transactions

Chile continues with the modernisation of its tax system

China: China introduces new free trade zones and improved practices

Colombia begins taxing indirect sales

Germany: How to adapt to the DEMPE concept when using third-party licensing agreements for transfer pricing

Greece: Analysing partial demergers

Hong Kong: IRD publishes long awaited practice notes on transfer pricing

India: Analysing foreign portfolio investor taxation in India

Indonesia: Indonesia issues a flurry of tax-related regulations

Israel: How the Israel tax authorities are interpreting intergroup intangibles exports

Italy: Italy issues guidelines on prevention of tax evasion

Luxembourg: Mandatory disclosure rules announced in Luxembourg

New Zealand: New Zealand government updates tax reform priorities

Poland: Poland introduces the white list of VAT taxpayers

Romania: The future of taxation in the digital era looks promising for Romania

Russia: Supreme Court issues decision on allocation of costs to income

South Africa: National Treasury releases proposed international tax amendments

Spain: Protocol of the Spain-US tax treaty enters into force

Switzerland: Swiss-US double tax treaty protocol enters into force

Thailand issues regulation on stamp duty payment for electronic documents

US inbound: IRS proposes new guidance for cloud transactions

US outbound: OECD statistics show continued effectiveness of MAP cases globally and in US

Features

Market insight

Tax transparency: Imperfect vision

Auditors rely on trust and verification methods

The B Team presents its business case for responsible tax

Beyond and beneath the arm’s-length principle

‘Ease of Doing Business’ Large taxpayer GST units necessary in India

Americas Tax Awards 2019: The winners

EU circular economy plans could cut tax costs for companies

Do new transparency obligations help us know our company better?

Tax Relief

Tax Relief

Special Features

News Analysis

Taxpayers surprised by India’s corporate tax cuts

EU court rules in favour of Starbucks, but against Fiat over state aid

First filings under UK Making Tax Digital go ‘fairly smoothly’

Mexico’s VAT reforms risk foreign digital platforms exiting market

India GST Council’s tax tweaks welcomed

OECD MAP statistics offer mixed views on dispute resolution

HMRC delays ‘sledgehammer’ VAT reverse charge

Glencore wins TP dispute against Australian Taxation Office

Editorial

Treading water

Sponsored

Sponsored

Sponsored by KPMG Russia

Russia: Supreme Court issues decision on allocation of costs to income

Dmitry Garaev and Anastasia Avdonina of KPMG discuss the Supreme Court’s decision A47-9881/2017 of August 26 2019, which is of specific interest for companies receiving both operating profit and dividend income.

Anastasia Avdonina, October 15, 2019
Sponsored by KPMG China

Hong Kong: IRD publishes long awaited practice notes on transfer pricing

Following the enactment of the transfer pricing (TP) legislation in Hong Kong on July 13 2018, the Hong Kong Inland Revenue Department (IRD) published on July 19 2019 the three long-awaited Departmental Interpretation and Practice Notes (DIPN) Numbers 58, 59 and 60.

Curtis Ng, October 15, 2019
Sponsored by Yaron-Eldar Paller Schwartz & Co

Israel: How the Israel tax authorities are interpreting intergroup intangibles exports

Henriette Fuchs of Yaron-Eldar Paller Schwartz & Co highlights increasing challenges in relation to intergroup intangible asset transactions in light of recent and progressing case law.

Henriette Fuchs, October 15, 2019

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