A former New Mexico state tax employee was sentenced to almost eight years in prison. He altered tax refunds and directed the money to accounts he controlled. National Taxpayer Advocate Erin Collins talks about the “balancing act” of her role, assesses the IRS backlog, and offers advice for practitioners and taxpayers in this podcast episode with transcript. The IRS also expanded and clarified the instructions for answering the question to help taxpayers answer it correctly. Taxpayers must answer the question even if they didn’t engage in activities involving digital assets, just as in the 2021 tax year. Although available to businesses of any size, the IRS expects the new Information Returns Intake System to be especially useful to small businesses that now file paper Forms 1099.

Therefore, it cannot compare the position of the beneficiary of a transfer pricing ruling with that of any other taxpayer in the same Member State, unless it can show that the transfer pricing rules systematically favour group companies over standalone companies. A further consultation will need to be conducted regarding other crucial aspects of an EU-wide WHT relief system. Such aspects are liability, entitlement under double tax treaties and potential exchange of information between financial authorities and tax authorities. A proposal for a directive regarding this initiative is expected to be presented in the first half of 2023. Measures to prevent double taxation will be included in the MLC to implement Amount A, with relief to be provided through either the exemption method or the credit method. The Department is still processing information in order to complete the Commerce Tax registration for taxpayers.

Personal Property Tax

This measure is peculiar given the intention of the European Commission’s DEBRA Proposal to address the debt-equity bias. The inbound taxpayer must earn a minimum gross annual Belgian income of EUR 75,000. This condition does not apply to inbound researchers, who are subject to some other specific conditions. The excess revenue will be used to finance the grant of an energy discount for Belgian households at the end of 2022/start of 2023. It should be noted that the Belgian proposal goes further than the EU proposal by using a EUR 130 threshold. On 1 November 2022, the Netherlands published a legislative proposal that implements the solidarity contribution outlined in the EU Regulation on an emergency intervention to address high energy prices. Following the EU measures to address high energy prices, the Dutch government intends to introduce a temporary solidarity contribution for Dutch companies active in the fossil industry.

• The DAC7 obligations cover both cross-border and purely domestic activities.
• There is however still a possibility that consensus will be reached during the upcoming ECOFIN meeting on 6 December 2022.
• The period means the reporting period for which the MNE prepares consolidated financial statements.
• The reason for this is that TNMM, unlike cost-plus or resale price methods, compares net margins instead of gross margins.
• The announcements made in the Communication will translate into legislative proposals in the years up to and including 2024 and will have a significant impact on MNEs’ taxation and reporting obligations.
• Furthermore, the EU ETS will be tightened for the aviation sector and will be extended to include maritime transport.

These new assessment periods will apply as of assessment year 2023 and only for the future. Information regarding the tax return was received from abroad that relates to reportable cross-border arrangements or to platform operators if the amount exceeds EUR 25,000. On 1 July 2022, the Minister for Legal Protection published its legislative proposal to introduce public country-by-country reporting obligations in the Netherlands. Based on this legislative proposal, the obligation will ultimately apply to certain multinationals with financial years starting on or after 22 June 2024. If the severance payment of an employee with an international employment history is subject to double taxation, the Dutch State Secretary of Finance has indicated that the Netherlands will, upon request, enter into a mutual agreement procedure based on the OECD commentary. In addition to the pure transparency measures adopted and/or proposed in the EU, it is worth considering certain tax reporting requirements included in the Unshell Proposal and the EU-wide system for withholding tax.

​​​ ​​​​How to calculate your rebate amount

As a result, we see an increasing variety of questions around working from home and especially around cross-border employment. It is recommended reviewing existing financing structures where the deductibility of interest payments is denied based on the Dutch anti-base erosion rules. Each jurisdiction has its own specific rules as to which subsidiaries will fall within the scope of the public country-by-country reporting obligations. It is recommended that MNEs assess in what jurisdictions and to what extent the new obligations may apply. The CARF is intended to ensure collection and exchange of information on transactions in crypto-assets in a manner similar to the Common Reporting Standard. Crypto-assets falling within the definition of the CARF include cryptocurrencies, stablecoins, derivatives issued in the form of crypto-assets, and certain non-fungible tokens.

• Under conditions, a company qualifies for the fiscal investment institution regime resulting in a 0% corporate income tax rate.
• Changes to the minimum ETD rates for fuels and electricity may, moreover, increase tax obligations in certain sectors.
• Under the existing rules, companies can carry forward tax losses indefinitely, but their use per taxable period is limited to EUR 1 million + 70% of the taxable result exceeding EUR 1 million.
• Further to this, almost all respondents strongly support the need for EU action to make the WHT procedures more efficient.
• A transfer of a business or part thereof may often be implemented in a tax neutral way.

This methodology is based on information that identifies the source of the revenues or, alternatively, based on an allocation key. At least EUR 1 million of revenue must be generated in a jurisdiction for an Amount A allocation. This threshold is reduced to EUR 250,000 for jurisdictions with a gross domestic product of less than EUR 40 billion. Ricardo Schmitz, Mykolas Romeris University, discusses new amendments to the Estonian transfer pricing rules, in force since January 1, with the goal of harmonizing domestic legislation with current OECD recommendations. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. The insights and services we provide help to create long-term value for clients, people and society, and to build trust in the capital markets. Please use this form if the NAICS code category for the current tax year is different form the NAICS code category selected on the initial Commerce Tax Return.

New transparency rules require service providers to report crypto-asset transactions

For both existing and new structures that involve Dutch SCs, taxpayers should therefore carefully assess the impact of the new TP Decree on a case-by-case basis. This will be especially relevant for SCs that rely on the application of Dutch tax treaties for the reduction of withholding taxes. The updated section on financial transactions in the TP Decree has been aligned with the content of Chapter X of the TPG. This section emphasises, amongst others, that it should first be determined whether a prima facie loan should be considered a loan for transfer pricing purposes. If adjusting the interest rate and/or other conditions of the loan transaction is not sufficient to make the transaction at arm’s length, part of the loan may be reclassified to equity for transfer pricing purposes.

The Kentucky Department of Revenue will begin processing electronic individual income tax returns on Feb. 6. Here you can read our recent Tax Newsletters, providing country updates and insights from BDO international tax professionals around the world. Our BDO international tax newsletters highlight recent developments in corporate international tax, indirect tax, tax and social security issues affecting international assignees, and transfer pricing. Again, the agreed or imposed price would be used for Dutch corporate income tax purposes if there is no such corresponding adjustment. If the applicable tax treaty holds that a tax credit applies for avoidance of double taxation in respect of a board member fee, the board member fee will, in the end, be taxable at the highest applicable tax rate of the two countries involved. For most Dutch tax resident members of the board of a foreign company this will, on balance, lead to a higher PIT on their foreign board member fee. The withdrawal of the approval will have no effect on situations where the tax treaty includes an exemption for avoidance of double taxation.

As part of the Department’s efforts to provide information to taxpayers about available credits, a new Commerce Tax Credit training is now available online. ​Probably not, unless you filed Individual Income Taxes in South Carolina in 2021. The rebate is for taxpayers who filed a 2021 South Carolina Individual Income Tax return.

We provide a calendar that shows the events we attend, as well as other events happening with us, such as interested party and Board meetings. Also, Virtual Hold technology for the Tax Practitioner Hotline will be available beginning March 1, 2023. This technology allows tax professionals to request a call https://turbo-tax.org/ back within a set time frame rather than having to wait on hold. As promised, the responses to the December 8, 2022, Taxpayer Bill of Rights Hearing issues and concerns are posted to the Your taxpayer rights | FTB.ca.gov webpage. For additional help using Web Pay, go to Help with bank account payments.

In transfer pricing, we see more and more multi-jurisdictional audits and multilateral agreement procedures. MNEs may want to prepare what to do in case they have to face these procedures. Upon the application approval, 50% of the commerce tax paid by other member of the affiliated group can be claimed as a credit against a modified business tax liability incurred by the designated payroll provider.

• In scope are Dutch corporate income taxpayers that realized at least 75% of their turnover through certain economic activities related to the production of oil and natural gas.
• Tax Exemption Budget – Provides information to facilitate a regular, comprehensive legislative review of tax exemptions.
• The platforms will then also have to pay VAT on the brokered turnover of other companies on their electronic platform.
• The IRS said that most electronic filers will receive their refund within 21 days if they choose direct deposit and there are no issues with their tax return.
• The proposed amendments to the EU ETS primarily consist of reducing the amount of emission allowances available.