KPMG practitioners from France, Ireland, Austria, Poland, and Italy discuss recent value added tax rulings from the Court of Justice of the European Union.

US tax treaty exchange of information provisions, such as that with Spain, can enable foreign tax authorities to obtain, from their own country’s banks’ US branches, information that may otherwise be practically unavailable to them due to US bank confidentiality laws, say Alan S. Lederman of Gunster, Yoakley & Stewart, P.A. and professor Mercedes Fuster Gómez of the University of Valencia.

KPMG Meijburg & Co. practitioners analyze the Dutch State Secretary for Finance’s 2023 annual report to Parliament on their ruling practice and discuss trends in ruling requests and the shift from unilateral to bilateral and multilateral APAs.

Proposed IRS rules would significantly increase reporting demands for Americans abroad and require meticulous compliance and proactive management to avoid penalties and protect beneficiary interests, say Arielle Tucker of Connected Financial Planning and Duncan Teed of Tax Logicians.

Recent OECD guidance relating to Pillars 2 and 1 represent continued progress in the implementation of the global minimum tax of Pillar 2 and the effort to implement the Amount B standard, but MNEs must continuously monitor guidance as many open issues remain, say DLA Piper practitioners.

Now that Brazil has officially shifted to a TP system largely consistent with the OECD Guidelines, MNEs operating in Brazil should quickly work to analyze and carefully document their Brazil operations for TP purposes—and try to minimize year-end TP adjustments, say KPMG practitioners.