KPMG’s Week in Tax: 13 - 17 June 2016

KPMG’s Week in Tax: 13 - 17 June 2016

Tax developments or tax-related items reported this week include the following items.

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Transfer Pricing

  • OECD: The OECD Council approved the incorporation of transfer pricing-related base erosion and profit shifting (BEPS) actions or amendments into the OECD’s Transfer Pricing Guidelines.
  • Luxembourg: A version of the EC’s decision to open a state aid investigation into a tax ruling obtained from the Luxembourg tax administration, by a U.S. branch of a multinational corporation, was released.

 

Read TaxNewsFlash-Transfer Pricing

Americas

  • Canada: Fund managers—including mutual and segregated fund managers—need to consider certain indirect tax (GST/HST and QST) requirements as the investment plans move to satisfy their indirect tax obligations by 30 June 2016.
  • Canada: Legislation in Ontario received Royal Assent, and with this enactment, a new Ontario retirement pension plan (ORPP) is established.
  • Canada: Legislation in Newfoundland enact certain corporate tax measures and tax rate increases as announced in Newfoundland's 2016 budget.
  • Paraguay: Paraguay agreed to implement an OECD program for an international standard of exchange of information on request and to work towards a practicable timeframe to implement the standard of automatic exchange of financial account information.

 

Read TaxNewsFlash-Americas

Asia Pacific

  • Japan: An agreement for the avoidance of double taxation, signed between associations in Japan and Taiwan, entered into force on 13 June 2016. 
  • Australia: An email that contains controlled technology, software or designs and sent to a recipient outside of Australia, may be an export and subject to Australian export controls.
  • Australia: State tax measures were included in the Queensland state budget.
  • Australia: Non-resident buyers of residential property may encounter significantly higher stamp duty (tax) costs in eastern Australia. 
  • Australia: There is a proposal to change the consolidation regime’s treatment of tax liabilities.
  • Cambodia: Representatives of the governments of Cambodia and Singapore on signed an agreement for the avoidance of double taxation. The treaty is pending ratification by Cambodia and Singapore. This is the first income tax treaty signed by Cambodia.
  • Thailand: Guidance provides additional deductions with respect to investments and capital investment spending for certain assets. To be eligible for the tax incentive, the expenditure must be made with respect to assets during the period 3 November 2015 - 31 December 2016.

 

Read TaxNewsFlash-Asia Pacific

Europe

  • Italy: The Italian revenue agency issued guidance concerning the 40% increase in depreciation that may be available with respect to investments in new tangible assets. 
  • Switzerland: Switzerland’s National Council adopted a final decision concerning a package of corporate tax reform referred to as “CTR III” or “corporate tax reform III.”
  • Belgium: A draft law would modify the “catch all” clause that imposes a withholding tax on Belgium-sourced income of non-residents that would have been taxable if the income had been received by Belgian residents (in both treaty and non-treaty situations). The draft law has been sent to the Council of State for advice, with the new clause scheduled to be effective 1 July 2016.

 

Read TaxNewsFlash-Europe

Africa

  • Nigeria: The Central Bank of Nigeria in June 2016 announced a “flexible” foreign exchange policy.

 

Read TaxNewsFlash-Africa

Exempt Organizations

  • The U.S. House of Representatives passed a bill that would bar the IRS from collecting the name, address, or other identifying information of any contributor making a contribution to or a grant, bequest, devise, or gift of money or property to a section 501(c) organization.

 

Read TaxNewsFlash-Exempt Organizations

FATCA / IGA / CRS

  • Reporting extensions: The FATCA reporting deadline was extended in the Cayman Islands, the British Virgin Islands, Liechtenstein, Romania, and Malta, and the FATCA reporting deadline was announced in Italy.
  • India: The Central Board of Direct Taxes (CBDT) issued clarifications with respect to implementation of FATCA and common reporting standard (CRS), following consultations with financial institutions.
  • UK: HM Revenue & Customs issued guidance relating to the automatic exchange of information by charities under the CRS.
  • Brazil: A new version of the FATCA reporting guidance was released.

 

Read TaxNewsFlash-FATCA / IGA / CRS

United States

  • IRS practice units: The IRS Large Business and International (LB&I) division released two practice units—or IRS examiner “job aides” and training materials—concern the tax treatment of scholarships and fellowship grants paid to nonresident aliens and situations when a Form 926 is not filed on the transfer of property to a foreign corporation.
  • Louisiana: House Bill 1121, pending action by the governor, adopts use tax reporting requirements for non-collecting remote sellers that make sales to Louisiana purchasers.
  • Massachusetts: The high court affirmed a lower court decision finding that certain deferred subscription arrangement transactions entered into between U.S. and U.K affiliates did not constitute bona fide debt for Massachusetts corporation excise tax purposes.
  • Oklahoma: New law reduces the statute of limitations for filing sales and use tax refund claims from three years to two years.

Read TaxNewsFlash-United States

 

  • The House Ways and Means Committee reported out (approved) seven health-related tax bills.

 

Read TaxNewsFlash-Legislative Updates

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