The US Internal Revenue Service is inviting public input on improvements to certain post-filing alternative dispute resolution (ADR) programs.
The IRS is interested in suggestions to improve the administration of these ADR programs and in proposals for other approaches to ADR that can increase the use and efficacy of ADR in the resolution of tax disputes. The IRS welcomes comments on all aspects of alternative dispute resolutions practices to help inform IRS policies for improving taxpayer service and resolving issues and cases fairly and expeditiously.
Comments must be received by August 25.
South African Revenue Service is seeking public input on draft tax bills.
The 2023 draft Taxation Laws Amendment Bill contains the necessary legislative amendments required to implement the more complex tax announcements made in the 2023 Budget Review relating to R&D tax incentive, clarifying anti-avoidance rules dealing with third-party backed shares, and refining the participation exemption for the sale of shares in foreign companies.
The 2023 draft Tax Administration Laws Amendment Bill contains legislative amendments dealing with tax administration such as APAs.
Comments must be received by August 31.
The OECD has issued administrative guidance on the global minimum tax rules.
Detailed administrative guidance has been published on currency conversion rules, the substance based income exclusion, and further guidance on the treatment of tax credits.
The two new safe harbours included in the package are a permanent safe harbour for jurisdictions that introduce a Qualified Domestic Minimum Top-up Tax (QDMTT), and a transitional UTPR Safe Harbour, which provides the UPE Jurisdiction with relief from the application of the UTPR for fiscal years commencing on or before the end of 2025.
Norwegian government has terminated tax treaties with Barbados, Curacao, Jamaica, Sierra Leone, and Trinidad and Tobago.
The terminations were published in the Royal Decree on June 9.
The terminations will take effect on January 1, 2024.
The OECD is inviting public input on its two-pillar solution to address digital economy taxation.
The OECD is seeking comments on the design elements of Amount B. Input is requested on ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities.
Comments must be received by September 1, 2023.
Ireland is consulting stakeholders on measures that would prevent double non-taxation arising from outbound payments to low or no tax jurisdictions.
The legislative measures would include withholding taxes on, or non-deductibility of, outbound payments. In the case of dividends, measures would include withholding taxes as dividends are non-deductible, to be completed by March 31, 2024.
Comments must be received by August 8.
Nearly all members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed to refrain from imposing newly enacted digital services taxes or relevant similar measures on any company before December 31, 2024, or the entry into force of the Multilateral Convention (MLC) if earlier, provided the signature of the MLC has made sufficient progress by the end of the year.
The commitment is made in recognition of the progress made to date and the need to prevent disruption or delay of the ratification of the MLC.
The agreement follows 20 months of intense technical negotiations by delegates to continue the work to implement the Two Pillar Solution.
Japan’s tax treaty with Azerbaijan will enter into force on August 4, 2023.
The treaty will be effective from January 1, 2024.
The provisions concerning the exchange of information and the assistance in the collection of taxes will have effect from August 4, 2023.
Brazil is consulting stakeholders on a draft Normative Instruction that would regulate the country’s new transfer pricing regime.
The Normative Instruction would cover several aspects of the new transfer pricing law as well as administrative issues related to transfer pricing.
Comments must be received by July 25.
Latvia’s Finance Ministry has published an updated list of tax havens.
The updated list includes the following tax jurisdictions: Anguilla, Bahamas, British Virgin Islands, Costa Rica, Fiji, Guam, Marshall Islands, Palau, Panama, Russia, Samoa, Trinidad and Tobago, Turks and Caicos Islands, US Virgin Islands, and Vanuatu.
The updated list came into force on July 1, 2023.
The Intra-European Organisation of Tax Administrations (IOTA) has terminated the membership of Russia and Belarus.
The decision was made by the 27th General Assembly of IOTA in Tbilisi, Georgia.
The termination of membership resulted from an absolute majority vote of IOTA members and came into effect on June 27, 2023.
Denmark’s Finance Ministry is consulting on a draft bill that would implement the EU Directive on Pillar Two into Danish tax law.
The draft bill proposes to introduce an income inclusion rule, an undertaxed profit rule and rules on a qualified domestic top-up tax.
The new rules are intended to come into force on January 1, 2024.