MNE Tax

Catch up with MNE Tax: OECD tax plan's unexpected costs I  Brazil's new TP regime I ECJ on DAC6, PE I new Belgian anti-tax evasion measure→ buff.ly/3uYyloR Never miss the news. Sign up to have MNE Tax delivered to your inbox→ buff.ly/2GtxQGP

Kyrgyzstan, Slovak Republic agree on draft of income tax treaty: AKIpress→ buff.ly/38Xxjkm For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: buff.ly/2GtxQGP

Singapore Telecommunications (Singtel) files appeal after Australian court ruled its subsidiary must pay an AUD 393 million tax bill: The Edge Markets→ buff.ly/3v311go For more international tax news→ buff.ly/3rU3d5L

Francisco Arballo, Grupo Consultor EFE, discusses Paraguay’s publication of rules for preparing local transfer pricing technical study report, sets deadline — MNE Tax — buff.ly/3rHBZl3

Belize, Cameroon deposit instruments of ratification for BEPS MLI with the OECD; entry into force is August 1 for both countries; Japan extends the application of the multilateral BEPS convention: OECD→ buff.ly/3LkExxr MNE Tax links: buff.ly/2xz9x8O

US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→ buff.ly/3xJ9mb6 For the latest tax and transfer pricing news, sign up for the MNE Tax newsletter: buff.ly/2GtxQGP

Alex M. Parker, Capitol Counsel LLC, discusses why muddled goals, broad scope lead to unexpected costs of OECD tax agreement — MNE Tax — buff.ly/37yDxqG

Nathalie Valluis, French tax lawyer, discusses how changes in Belgian tools to fight tax evasion are impacting French financial institutions — MNE Tax — buff.ly/3jWqFgD

Luca Tortorella and Michele Targa, Gatti Pavesi Bianchi Ludovici, discuss the ECJ AG’s opinion on issues relating to protection of legal privilege in the context of exchange of information obligations under DAC6 — MNE Tax — buff.ly/3KXwxlv

Assistant Secretary for Tax Policy Lily Batchelder says Biden Administration is optimistic that the US will enact Pillar Two in 2022: Lily Batchelder / US Dept of Treasury→ buff.ly/37saoxi MNE Tax links: buff.ly/2xz9x8O

Adrian ȚAGA, Romania’s National Tax Agency, discusses CJEU ruling on intragroup transaction concerning VAT concept of permanent establishment — MNE Tax — buff.ly/3uSHnUj

Ireland seeks comments by May 30 on R&D tax credit, `Knowledge Development Box,’ an intellectual property regime providing relief from corp tax on income arising from qualifying assets: Irish Ministry of Finance→ buff.ly/3OdH3r3 MNE Tax links: buff.ly/2xz9x8O

Patrick Donsimoni, La Boetie, discusses characterization as a resident for withholding tax exemption under tax treaties signed by France — MNE Tax — buff.ly/36hse5C

OECD seeks public comments by April 29 on extractives exclusion under Amount A of Pillar One. The extractives exclusion will exclude from the scope of Amount A the profits from extractive activities: OECD→ buff.ly/3KOpyLJ MNE Tax links: buff.ly/2xz9x8O

OECD unveils stage 2 peer reviews under BEPS Action 14 regarding mutual agreement procedure (MAP) for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau, Morocco & Tunisia: OECD→ buff.ly/3EdWRFu MNE Tax links: buff.ly/2xz9x8O

Francisco Lisboa Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the details of Brazil's new transfer pricing regime — MNE Tax — buff.ly/3uGfcI4

Catch up with MNE Tax: US budget I Singtel I Estonian TP I Norway v. ConocoPhillips, Exxon I Bahrain corporate tax I Decriminalizing marijuana I US SEC v. Amazon→ buff.ly/3uFVsnW Never miss the news. Sign up to have MNE Tax delivered to you→ buff.ly/2GtxQGP

New IMF report says large portion of MNEs’ profit reflects excess profit, which is efficient to tax because it does not distort investment decisions: International Monetary Fund→ buff.ly/3KIuHF3 MNE Tax links: buff.ly/2xz9x8O

Kyle Pomerleau, American Enterprise Institute, warns US President Biden’s tax reforms could leave US multinational corporations at a competitive disadvantage — MNE Tax — buff.ly/37lbESG

Annemarie Wilmore, Johnson Winter & Slattery, discusses interest on inbound financing: is it arm’s length? — MNE Tax — buff.ly/3O5wndS