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International Tax News & Updates

New Zealand, Slovakia sign tax treaty

9/29/2023

 
New Zealand and Slovakia signed a tax treaty on September 26.

The tax treaty incorporates the OECD’s BEPS proposals and is generally in line with international tax law practice.
​
The details of the treaty would be reported when available.

Progress continues in strengthening tax transparency through CbC reporting

9/27/2023

 
The OECD has released the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs, demonstrating strong progress in international efforts.

The sixth annual peer review of BEPS Action 13 considers implementation of the CbC reporting minimum standard by jurisdictions as of April 2023 and covers 136 Inclusive Framework members. Highlights include:

  • Over 110 jurisdictions have already introduced legislation to impose a filing obligation on MNE groups, covering practically all MNE Groups with consolidated group revenue at or above the threshold of EUR 750 million. Remaining Inclusive Framework members are working towards finalizing their domestic legal frameworks with the support of the OECD.
  • Where legislation is in place, the implementation of CbC reporting has been found largely consistent with the Action 13 minimum standard.
  • A large number of recommendations made in the first five peer review phases have now been addressed and these recommendations have been removed.
  • More than 3 000 bilateral relationships for the exchange of CbC reports are now in place.

OECD publishes public comments on Amount B under Pillar 1

9/20/2023

 
The OECD has released public comments received on Amount B under Pillar One relating to the simplification of transfer pricing rules.

Amount B provides for a simplified and streamlined approach to the application of the arm's length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries.
​
The comments may be viewed on the OECD’s website.

Australia to release corporate tax transparency report in November

9/12/2023

 
The Australian Taxation Office will publish, in early November, the income tax information of large companies for the income year 2021–22.

Information will be published on Australian public or foreign owned entities with a total income of AUD 100 million or more; Australian resident private companies with a total income of AUD 200 million or more; and entities reporting petroleum resource rent tax payable.
​
The Australian Taxation Office said it will write to companies in September with the reported tax information it plans to publish, and outlining the steps companies may take to correct errors.

India signs record bilateral APAs

9/6/2023

 
Indian tax authority has signed a record number of bilateral advance pricing agreement (APAs) in the 2022-23 financial year.

According to the latest APA report, the tax authority signed the highest number of APAs in the 2022-23 financial year since the launch of the APA program.
​
More than half of bilateral APA applications are with the US. Other treaty partners with whom large number of applications have been filed in the 2022-23 financial year are Japan, Finland, South Korea, and the UK.

New Zealand mulling digital services tax in 2025

9/1/2023

 
New Zealand will implement a digital services tax in 2025 if international agreement on the issue fails to pass through, Finance Minister Grant Robertson has said.

The proposed digital services tax will target large multinational businesses that earn income from New Zealand users of social media platforms, internet search engines, and online marketplaces.
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The proposed tax would be payable by multinational businesses that make over EUR 750 million a year from global digital services and over NZD 3.5 million a year from digital services provided to New Zealand users.
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