ATL-Editor

OECD – Release of Revenue Statistics in Africa 2019

The average tax-to-GDP ratio for the 26 countries participating in the new edition of Revenue Statistics in Africa was unchanged at 17.2{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} for the third consecutive year in 2017. This was lower than the averages for Latin America and the Caribbean (LAC) at 22.8{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} and for the OECD at 34.2{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}, underlining the need for urgent action to enhance […]

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TAX PLANNING AS PART OF A TAX RISK MANAGEMENT PROCESS Makes SSRN Top 10

Dear Dr Daniel N. Erasmus: Your paper, “TAX PLANNING AS PART OF A TAX RISK MANAGEMENT PROCESS”, was recently listed on SSRN’s Top Ten download list for: ERN: Criteria for Decision-Making under Risk & Uncertainty (Topic). As of 20 November 2019, your paper has been downloaded 1,281 times. You may view the abstract and download

TAX PLANNING AS PART OF A TAX RISK MANAGEMENT PROCESS Makes SSRN Top 10 Read More »

US Tax Court resolves Eaton’s transfer pricing dispute – By Elisa Kaminsky, BaseFirma, Miami

The US Tax Court issued a written opinion on October 28 regarding Eaton’s transfer pricing court case. The resolution of the case was in favor of Eaton, and it determined the IRS abused its discretion when canceling advance pricing agreements the company had in place. Eaton’s transfer pricing dispute Eaton and its subsidiaries entered into

US Tax Court resolves Eaton’s transfer pricing dispute – By Elisa Kaminsky, BaseFirma, Miami Read More »

Poland’s new cooperative compliance program for large taxpayers – By Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics

On 6 November, Poland’s President signed a law implementing a new cooperative compliance program in Poland for large corporate taxpayers (also referred to as horizontal auditing). This is a new tax institution in Poland that introduces collaboration between taxpayers and the tax authorities. The program is available to taxpayers with tax turnover of over 50

Poland’s new cooperative compliance program for large taxpayers – By Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics Read More »

The United Nations’ effort to shape global transfer pricing policy – By George L. Salis, Principal Economist & Tax Policy Advisor, Vertex, Inc., King of Prussia, Pennsylvania

The 19th Session of the United Nations Committee of Experts on International Cooperation in Tax Matters was held October 15-18 in Geneva. This session, like the prior one, mainly focused on the role that taxation is playing in raising domestic resources to finance sustainable development goals, as recently set forth in the Addis Ababa Action

The United Nations’ effort to shape global transfer pricing policy – By George L. Salis, Principal Economist & Tax Policy Advisor, Vertex, Inc., King of Prussia, Pennsylvania Read More »

OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals – By Julie Martin, MNE Tax

The OECD on November 15 published more than 300 comment letters that respond to its request for feedback on the Secretariat’s proposal for a “unified approach” to pillar one. The OECD Secretariat’s proposal, released October 9, aims to expedite agreement among a coalition of 130+ nations that make up the “Inclusive Framework on BEPS” on an update

OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals – By Julie Martin, MNE Tax Read More »

China simplifies procedure for claiming tax treaty benefits – By Agnes Lo, Lingnan University, Hong Kong & Raymond Wong, Associate Dean, City University of Hong Kong

China’s State Taxation Administration on 14 October published “Administrative Measures for Non-resident Taxpayers Claiming Tax Treaty Benefits” [Announcement (2019) No. 35]. Announcement (2019) No. 35 will become effective from 1 January 2020, and will replace existing Announcement (2015) No. 60. The new regulation simplifies filing procedures for claiming tax treaty benefits by non-resident taxpayers. It

China simplifies procedure for claiming tax treaty benefits – By Agnes Lo, Lingnan University, Hong Kong & Raymond Wong, Associate Dean, City University of Hong Kong Read More »

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes – By Julie Martin, MNE Tax

The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border tax dispute resolution process in Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab Emirates, and Vietnam. Taxpayers are invited to submit comments on their experiences

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes – By Julie Martin, MNE Tax Read More »

Colombia issues new guidance on the taxation of permanent establishments and branches – By Carlos Subero, Senior Consultant, BaseFirma Colombia

On October 29, the Colombian government published Decree 1973, providing detailed rules on the attribution of income to a permanent establishment or branch of a multinational corporation. According to the new guidance, foreign companies and entities must pay income tax on their income and occasional earnings in Colombia, regardless of whether they receive such income

Colombia issues new guidance on the taxation of permanent establishments and branches – By Carlos Subero, Senior Consultant, BaseFirma Colombia Read More »