Winter 2021

Main

ITR Global Tax 50 2020-21

Market insight

From intern to global vice chair: Lessons learned from EY’s Kate Barton

US tax reform: A new administration and remedy

Indian court confirms Redington’s use of foreign subsidiaries avoided tax

Taxation of plastics could trigger a litigation wave

What taxpayers can expect in 2021

ITR Awards 2021 and World Tax/World TP rankings research now open for submissions

Ensuring effective AEOI: Global Forum’s peer reviews set direction for 2021/2022

What direct tax teams can learn from indirect tax innovation

Countdown to digital tax

Financial sector prepares for significant tax changes

US TP Forum

How to prepare for the OECD digital tax reforms

China strengthens litigation framework through increased use of APAs and MAPs

How COVID-19 has impacted global M&A activity

Biden administration has positive outlook on digital tax negotiations

UK opts out of DAC6 to follow OECD rules after Brexit

Facebook’s decision to shift IP to US reflects industry tax concerns

Improved clarity on IR35 changes proving useful for UK MNEs

News in brief

Tax Relief

Australia: ATO announces guidance on withholding tax concessions and updates APA procedures

Brazil: STJ confirms the triggering event for withholding tax

Chile: IRS issues guidance on requirements for the DDT treaty scenario to apply

China: FDI restrictions continue to be relaxed

France: Twin cases reduce the scope of taxing capital gains on sale of French shares

Germany: Taxation of the digital economy - Analysing user base value

Greece: ASC rules on the tax treatment of interest-bearing loans concerning stamp duty and VAT

Hong Kong SAR: IRD issues guidance on ship leasing tax concessions

India: Tax treaty overrides dividend distribution tax, rules Delhi Tax Tribunal

Indonesia: Interest rate changes for penalties wrap up a busy 2020

Italy: The case law on non-interest bearing loans and the arm’s-length principle

Luxembourg: Mapping the EU’s path to sustainable tax governance

Mexico: Assessing the tax reforms of 2021

Netherlands: Recovery of VAT - CJEU rules that actual use takes precedence over intention

New Zealand: IRD considers application of WHT rules to negative interest payments

Romania: Considerations on country-by-country reporting requirements

Poland: Changes for limited partnerships lead 2021 tax developments

Singapore: Non-budget amendments from the Income Tax Amendment Bill 2020

25 years of Swiss VAT: The partnership with the Principality of Liechtenstein

Thailand: A closer look at the updates to CbCR

US: New horizons for dispute resolution under pillar one’s Amount A

Cover Story

ITR Global Tax 50 2020-21

International Correspondents

Australia: ATO announces guidance on withholding tax concessions and updates APA procedures

Brazil: STJ confirms the triggering event for withholding tax

Chile: IRS issues guidance on requirements for the DDT treaty scenario to apply

China: FDI restrictions continue to be relaxed

France: Twin cases reduce the scope of taxing capital gains on sale of French shares

Germany: Taxation of the digital economy - Analysing user base value

Greece: ASC rules on the tax treatment of interest-bearing loans concerning stamp duty and VAT

Hong Kong SAR: IRD issues guidance on ship leasing tax concessions

India: Tax treaty overrides dividend distribution tax, rules Delhi Tax Tribunal

Indonesia: Interest rate changes for penalties wrap up a busy 2020

Italy: The case law on non-interest bearing loans and the arm’s-length principle

Luxembourg: Mapping the EU’s path to sustainable tax governance

Mexico: Assessing the tax reforms of 2021

Netherlands: Recovery of VAT - CJEU rules that actual use takes precedence over intention

New Zealand: IRD considers application of WHT rules to negative interest payments

Romania: Considerations on country-by-country reporting requirements

Poland: Changes for limited partnerships lead 2021 tax developments

Singapore: Non-budget amendments from the Income Tax Amendment Bill 2020

25 years of Swiss VAT: The partnership with the Principality of Liechtenstein

Thailand: A closer look at the updates to CbCR

US: New horizons for dispute resolution under pillar one’s Amount A

Features

Market insight

From intern to global vice chair: Lessons learned from EY’s Kate Barton

US tax reform: A new administration and remedy

Indian court confirms Redington’s use of foreign subsidiaries avoided tax

Taxation of plastics could trigger a litigation wave

What taxpayers can expect in 2021

ITR Awards 2021 and World Tax/World TP rankings research now open for submissions

Ensuring effective AEOI: Global Forum’s peer reviews set direction for 2021/2022

What direct tax teams can learn from indirect tax innovation

Countdown to digital tax

Financial sector prepares for significant tax changes

US TP Forum

How to prepare for the OECD digital tax reforms

Tax Relief

Tax Relief

Special Features

China strengthens litigation framework through increased use of APAs and MAPs

How COVID-19 has impacted global M&A activity

News Analysis

Biden administration has positive outlook on digital tax negotiations

UK opts out of DAC6 to follow OECD rules after Brexit

Facebook’s decision to shift IP to US reflects industry tax concerns

Improved clarity on IR35 changes proving useful for UK MNEs

News in brief

Editorial

Sponsored

Sponsored

Sponsored by Deloitte UK

How COVID-19 has impacted global M&A activity

Deloitte’s practitioners from across the globe assess how transactional activity has evolved as a result of the coronavirus pandemic and consider the key aspects of the new deal landscape.

Amrish Shah, January 28 2021
Sponsored by Sumerson

France: Twin cases reduce the scope of taxing capital gains on sale of French shares

Nicolas Duboille and Alexia Dal Ponte of Sumerson analyse recent case law concerning the application of the French capital gain tax applicable to non-resident entities on the transfer of a significant shareholding in a French entity.

Alexia Dal Ponte, January 25 2021
Sponsored by KPMG China

China strengthens litigation framework through increased use of APAs and MAPs

Xiaoyue Wang and Choon Beng Teoh of KPMG China explain how recent developments affirm the programmes’ effectiveness in providing certainty to transfer pricing arrangements in China.

Choon Beng Teoh, January 20 2021

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