OECD Tax Talk Outlines Latest Developments
On 27 February 2023 the OECD gave an update of recent developments in their tax work. G20 Chair’s summary The G20 Chair’s summary following the meeting of G20 finance ministers and central bank governors confirmed that the G20 remains
See MoreOECD Report to the February 2023 Meeting of G20 Finance Ministers
On 24 February 2023 the OECD published its report to the February 2023 meeting of the G20 Finance Ministers and Central Bank Governors. Inclusive Framework The report notes that the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework)
See MoreCzech Republic revises Non-Cooperative jurisdictions list for CFC Rules
On 24 February 2023, the Czech Republic released Financial Bulletin No. 3/2023, that announced the non-cooperative jurisdictions list for the Czech Republic's controlled foreign company (CFC) regulations. The list has been updated in accordance with
See MoreUK: Research on Taxpayer Experience of the Profit Diversion Compliance Facility
On 7 February 2023 HMRC published the results of research commissioned in order to understand taxpayers’ experience of the Profit Diversion Compliance Facility (PDCF) and Diverted Profits enquiry process. The research was conducted through
See MoreOECD: Technical Guidance for Implementation of the Global Minimum Tax
On 2 February 2023 the Inclusive Framework released technical guidance on implementation by governments of the global minimum tax. The Agreed Administrative Guidance for the Pillar Two GloBE Rules aims to ensure co-ordinated outcomes and greater tax
See MoreOECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
See MoreOECD: Public comments received on the design elements of Amount B under Pillar One
On 30 January 2023 the OECD published the comments received on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules. Comments were received from more than sixty businesses, institutes, NGOs and
See MoreOECD: Comments received on Draft MLC under Amount A of Pillar One
On 24 January 2023 the OECD published the responses received to the public consultation on the Draft Multilateral Convention (MLC) Provisions on Digital Services Taxes (DSTs) and other Relevant Similar Measures under Amount A of Pillar One. The
See MoreOECD: Revised Methodology for the BEPS Action 14 Peer Reviews
On 24 January 2023 the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) agreed a new assessment methodology for continuing the peer review process under BEPS action 14 to improve tax dispute resolution mechanisms. The
See MoreOECD: Revenue Impact of International Tax Reform
During a live webinar on 18 January 2023 the OECD presented the findings of a new analysis of the estimated impact on tax revenue of the implementation of the two-pillar international tax reform. The new analysis carried out by the OECD indicates
See MoreBelgium amends guidance on interest deduction rule
On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation starting from 1 January 2019, in line with the EU Anti-Tax Avoidance Directive (ATAD). A summary
See MoreSingapore: IRAS releases guidance on tax treatment of gains or losses from the sale of foreign assets
On 8 December 2023, the Inland Revenue Authority of Singapore (IRAS) released an updated e-tax guide on the tax treatment of gains or losses from the sale of foreign assets under the recently introduced Section 10(L) of the Income Tax Act (ITA).
See MoreIASB: Proposed Amendments to IAS 12 Arising from Pillar Two Rules
In January 2023 the International Accounting Standards Board (IASB) issued an Exposure Draft with proposed amendments to IAS 12 (Income Taxes). The amendments relate to tax and accounting implications of the implementation of the global minimum
See MoreUruguay revises list of low tax countries
On 28 December 2022, the Uruguayan Tax Administration released Resolution No. 2470/022, which updated the list of low or no taxation countries or jurisdictions. On 29 December 2022, the Resolution was published in the Official Gazette and entered
See MoreIreland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
See MoreTaiwan provides the list of low-tax jurisdictions under CFC rules
On 13 December 2022, the Ministry of Finance of Taiwan issued a press release providing the list of low-tax jurisdictions under controlled foreign company (CFC) rules. The CFC rules will be effective from 1 January 2023 for profit-making enterprises
See MoreOECD: Tax certainty for Pillar Two rules
On 20 December 2022 the OECD issued a consultation document on providing tax certainty under the Pillar Two GloBE rules. Comments are invited from interested parties by 3 February 2023. The GloBE rules are to be enacted by each jurisdiction into
See MoreRussia updates non cooperative Jurisdictions list for CFC purpose
On 5 December 2022, the Federal Tax Service of Russia published Order No. ED-7-17/987 in the Official Gazette which provides an update list of jurisdictions that do not have acceptable tax information exchange with Russia. The list applies in
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