Australia: 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
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreMexico modifies the General Customs Rules for 2020
On 24 July 2020, Mexico has published the first amendment to the General Customs Rules for 2020 in the Official Gazette. The amendments include changes to the Comprehensive Business Certification Scheme, in the VAT, VAT Certification and Authorized
See MoreUN: Draft Model Treaty Provision on Digital Services
On 6 August 2020 the United Nations (UN) published draft Article 12B for the UN Model Double Taxation Convention, to provide for the allocation of taxable income from automated digital services. The draft Article states that income from
See MoreOECD: Case Study on BEPS in the Mining Sector in Zambia
On 30 July 2020 the OECD published on its website a case study summarising assistance given to Zambia’s tax administration in relation to base erosion and profit shifting (BEPS) in the mining sector. The case study details how support was given
See MoreDAC6 Updates: Optional deferral of DAC6 reporting deadlines
On 24 June 2020, the European Council reached agreement on an optional 6-month postponement to the reporting deadlines for relevant taxpayers under EU Directive 2018/822 (DAC6), and a delay to the exchange of information under
See MoreEU: Court Annuls decision of European Commission on Irish State Aid to Apple
A press release of 15 July 2020 stated that the General Court of the European Union has annulled the European Commission’s decision that tax rulings by Ireland in favour of Apple amounted to illegal state aid. The press release noted that the
See More