OECD publishes public comments on proposals on taxation of the digital economy
On 16 December 2020 the OECD published comments received on the Blueprints outlining the remaining issues involved in finalising the work on Pillar One and Pillar Two of the proposals on tax challenges arising from the digitalisation of the
See MoreArgentina: Government publishes Budget Law for 2021
On 14 December 2020, the Government Officially published Law 27591 of 14 December 2020, including budget measures for 2021 to Congress amid continuing pandemic and political uncertainties. The measures are given below: The VAT and customs duties
See MoreOECD: Implementation of transfer pricing for hard-to-value intangibles
On 16 December 2020 the OECD published information setting out the extent to which member countries of the Inclusive Framework have implemented the recommendations on hard to value intangibles (HTVI) drawn up as part of the OECD/G20 project on base
See MoreGerman Upper House Approves MLI to Implement Tax Treaty Related BEPS Measures
On 6 November 2020 the Bundesrat (the upper house in the German parliament) gave its approval to ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the
See MoreOECD: Update on Peer Reviews of Harmful Tax Practices
On 23 November 2020 the OECD published an update on its work in relation to harmful tax practices. Harmful tax practices are highly favourable tax rulings or preferential tax rules or regimes intended to attract foreign income, potentially
See MoreUN: Proposed Treaty Article on Income from Automated Digital Services
Report by James R. Border, Law Office of James R. Border, P.A., Fort Lauderdale, Florida Over the past several days the UN Committee of Experts on International Cooperation in Tax Matters discussed the work done by Members concerning the tax
See MoreAustralia: Federal Court rules on tax position of UK citizen in Australia with a Working Holiday Visa
In a judgment of 6 August 2020 the Australian Federal Court ruled in favour of the Commissioner of Taxation in a case involving the residency test for a UK citizen staying in Australia on a Working Holiday Visa (WHV). The Court found that the UK
See MoreUkraine: MOF develops a regulatory framework for the execution of the BEPS
On 20 October 2020, the Ukrainian Ministry of Finance (MOF) has issued a press release regarding Implementation of the Law No 466 in Part of the BEPS Plan. MOF stated that they will approve all necessary regulations on the implementation of the
See MoreUN: Tax Committee discusses UN Model Commentary Issues – PE, treatment of software, CIVs
A report by James R. Border, Law Office of James R Border P.A., Fort Lauderdale, Florida On 22 October 2020 the United Nations Committee of Experts on International Tax Matters addressed several items relating to the UN Model Tax Convention.
See MoreOECD: Batch of Peer Review Reports on Dispute Resolution Mechanisms
On 22 October 2020 the OECD released a further batch of stage 2 peer review reports on tax dispute resolution mechanisms under BEPS Action 14. The minimum standard under BEPS action 14 is concerned with improving tax dispute resolution
See MoreOECD: Economic Impact of Pillar One and Pillar Two
At a presentation on 12 October 2020 introducing Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the digital economy, the OECD presented an economic impact analysis of the proposals. Pillar One Pillar One would
See MoreOECD: Report on Blueprint for Pillar Two of Digital Economy Taxation
On 12 October 2020 the OECD introduced a report on the Pillar Two Blueprint on digital economy taxation. Pillar Two aims to ensure that large multinational enterprises pay a minimum level of tax regardless of the location of their headquarters
See MoreOECD: Report on Pillar One Blueprint on Digital Economy Taxation
On 12 October 2020 the OECD introduced a report on the Pillar One Blueprint on digital economy taxation. Pillar One consists of a new taxing right for market jurisdictions over a share of residual profit calculated at an MNE group or segment
See MoreOECD: Reports on Blueprints for Pillars One and Two of Digital Economy Tax Proposals
Following a meeting of the OECD’s Inclusive Framework on 8 and 9 October 2020 the OECD held a presentation on 12 October 2020 to introduce Blueprint reports on Pillar 1 and Pillar 2 of the proposals on taxation of the digital economy. Public
See MoreUN: Committee of Tax Experts to Hold 21st Meeting
The 21st Session of the United Nations Committee of Experts on International Cooperation on Tax Matters will take place from 20 October 2020 to 6 November 2020. The session will be held in scaled-down format using a virtual platform, with virtual
See MoreOECD: Phase 3 Peer Review Reports on Country by Country Reporting
On 24 September 2020, the OECD published a compilation of Phase 3 peer review reports on Country by Country (CbC) Reporting under Action 13 of the action plan on base erosion and profit shifting (BEPS). The OECD/G20 Inclusive Framework on BEPS,
See MoreEU: Report on the VAT Gap in the EU Member States
In a press release of 10 September 2020, the European Commission presented the 2020 Study and Reports on the VAT Gap in the 28 EU Member States. The report presents figures on the VAT Gap in the 28 EU member states (including the UK) for
See MoreUK: VAT on Early Termination Fees and Compensation Payments
On 2 September 2020 the UK issued Revenue and Customs Brief 12 (2020) in relation to VAT on early termination fees and compensation payments. The previous guidance was that payments charged to withdraw from agreements to receive goods or
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