In Spain, the Government has decided to pump the brakes on the administrative requirements relating to the new Financial Transactions Tax, with the tax authority announcing a further extension to compliance deadlines for taxpayers liable to the country’s new financial transactions tax.
Spain’s financial transactions tax applies to the shares of Spanish companies with a market capitalization of EUR1bn or more. It features a 0.2 percent rate, and bonds and derivatives are excluded from its scope. The tax was introduced in Law 5/2020 of October 15, 2020, on the Tax on Financial Transactions, which became effective on January 16, 2021.
Financial transaction tax returns are to be due monthly. Typically, the return will be due between the 10th and the 20th of the month following the relevant month.
Previously, the tax agency had stated that taxpayers would not be required to submit their … Read More »
In the United States, it emerged that the US is still considering introducing taxes on six countries’ exports in response to their digital services tax regimes.
On March 26, 2021, the US Trade Representative (USTR) announced the next steps in its Section 301 investigations of digital services taxes adopted or under consideration by 10 US trading partners.
In June 2020, USTR initiated investigations into digital services taxes proposed or introduced in Austria, Brazil, the Czech Republic, the EU, India, Indonesia, Italy, Spain, Turkey, and the UK.
In January 2021, the USTR concluded that the digital services taxes adopted in Austria, India, Spain, Turkey, and the UK were discriminated against US digital companies, were inconsistent with principles of international taxation, and burdened US companies. It considered these are actionable under Section 301 of the Trade Act of 1974, which gives the USTR broad authority … Read More »
In Ireland, the Finance Department has launched a consultation (running until April 16) on proposed changes to the transfer pricing regime, focusing on the attribution of profits to branches of non-resident companies.
The proposed changes would extend transfer pricing rules to the taxation of branches in Ireland, in line with the Authorized OECD Approach (AOA).
The AOA seeks to ensure that profits from intra-group dealings are attributed to a permanent establishment, or branch, that would have been earned if the branch or PE were a legally distinct and separate enterprise from the head office. These profits are determined with reference to the profits that would been earned by an unrelated party undertaking the same or similar functions under the same or similar conditions.
For more information on this, and other topical international tax matters, please visit: https://www.cchgroup.com/roles/corporations/international-solutions/research/global-tax-weekly-a-closer-look