October/November 2019

Main
Cover Story
International Correspondents
Features
Tax Relief
Special Features
News Analysis
Editorial

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 PwC Brazil

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

On July 1 2019, the Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 210/2019 (dated June 24 2019), providing that withholding tax should be levied at a rate of 15% on interest that is accrued but not yet due, where the outstanding debt is used to reduce accounting losses of a Brazilian company via a ‘debit to shareholders account’ transaction.

Mark Conomy, October 15 2019
Sponsored by KPMG China

China: China introduces new free trade zones and improved practices

Since 2013 China has established an increasing number of free trade zones (FTZs) around the country.

Khoonming Ho, October 15 2019

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