KPMG’s Week in Tax: 1-5 February 2016

KPMG’s Week in Tax: 1-5 February 2016

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

Related content

Americas

  • Canada: A guide on taxation of the mining sector, with descriptions of Canada’s federal and provincial income tax law applicable to domestic and foreign mining activities
  • Canada: Tax measures in New Brunswick’s 2016 budget
  • Canada: Proposed legislation to provide relief from potentially harsh tax consequences of extending tax loss restriction rules to trusts

Asia Pacific

  • Australia: A review of stamp duty changes that may affect business taxpayers
  • India: A decision of the Delhi High Court held that activities of the taxpayer’s project office did not constitute a permanent establishment under the tax treaty with the UAE
  • Australia: Legislative changes pending for managed investment trusts (MITs) to elect to become AMITs and when to make such an election
  • Hong Kong: A new income tax treaty signed with Russia
  • Singapore: Liberalisation of the construction sector rules in India and opportunities for Singapore builders
  • Vietnam: Changes to the labour and compulsory insurance regulations, generally beginning 1 January 2016, affecting a company’s employment costs

Europe

  • EU: Explanatory notes regarding the rules for the location where value added tax (VAT) is imposed with respect to the supply of services connected with immovable property
  • Netherlands: Pending legislation concerning withholding of payroll tax and social security contributions and implications for board members
  • Serbia: Individual income tax returns for 2015 due date of 16 May 2016
  • Germany: Proposed legislative changes to reform the taxation of investment income
  • Netherlands: Dutch Supreme Court decision, “crisis levy” imposed on employers with respect to salary paid certain employees not a violation of the right to property

Transfer Pricing

  • Singapore: Reminder of goods and services tax implications arising from transfer pricing adjustments
  • Nigeria / Senegal: Nigeria and Senegal each have signed the Multilateral Competent Authority Agreement (MCAA) for implementing country-by-country reporting with other countries
  • United States: The IRS Advance Pricing and Mutual Agreement office beginning 16 February 2016, to accept requests for bilateral advance pricing agreements (APAs) between the United States and India
  • India: The first two bilateral APAs with the UK are signed, concerning management charges and brand royalty
  • South Africa: Proposals for mandatory transfer pricing documentation 

United States

  • House Republicans form task forces, including one to address tax reform
  • The Federal Circuit affirmed a trade court decision, that a U.S. automobile manufacturer was not entitled to a refund of overpayments of customs duties claimed in reconciliation entries
  • Regulations concerning a safe harbor rules used for determining whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners’ interests in the partnership
  • Puerto Rico looks to collect outstanding balances in taxpayers’ accounts
  • The Seventh Circuit rejected a taxpayer’s claim that an IRS summons was a “re-inspection” of previously examined records because the tax year under examination was not the same as a previously examined year (for which the records were summoned)
  • LB&I practice units on inter-company interest rates, cost sharing arrangements

 

Read these and other items reported this week at the TaxNewsFlash United States and Global websites

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