Greetings and Happy Tuesday! This is Tax Roast, a weekly newsletter that brings you the latest updates and insights from the international tax world from tax experts (and coffee enthusiast) who are walking the tax advisory path.

And do not forget to check out our coffee of the week, because there is no tax news without a good cup of coffee :)

International Tax Update

Dominican Republic/ CbCR e-Portal is available

The Dominican tax authority has put online the e-Portal to facilitate Electronics fixing of CbCR. The Portal also offers FAQs and manuals. It can be accessed HERE.

Ireland / Ireland broadens scope of anti-hybrid rules

In its latest guidance released, the Irish legislator has broadened the scope of “entity” under its anti-hybrid rules. The definition now includes any legal arrangement of whatever nature or form which is subject to tax. The complete updated guidance can be found HERE.

Honduras / requirement to submit statistical information to benefit from tax regimes

The government of Honduras has clarified that corporate taxpayers benefitting from tax regimes are now required to file tax returns and statistical reports in January and July each year if they want to continue to benefit from the tax regime such as e.g. free trade zones.

India / High Court clarifies statute of limitations

The Bombay High Court has has clarified under which conditions the tax authorities may reassess or reopen a tax file. The court stated that a reopening of a tax year after the 6 years statute of limitations shall only be possible if a reassessment notice is issued within the statute of limitations. For more info, check out this article.

Fun Tax Fact :)

Today we searched for a fun tax fact about Maine, US - here it goes 🙂 

Ever wondered why blueberries are often more expensive in the supermarkets than other berries? Probably it has to do with the demand and the production intensity but could tax also be a driver? Well, maybe if you live in the State of Maine, US it could. D

id you know that Maine levies a tax on blueberries? That’s right… apparently the tax is levied in order to protect the blueberries growing in the wild. So next time you are having your wild Maine blueberries, maybe you want to savor them even a bit more…

Global minimum tax / Pillar 2 bootcamp

Everybody keeps hearing the term ‘Constituent Entity’ or ‘CE’ from their tax advisors when they start talking about Pillar 2. But does a Constituent Entity mean exactly? Is it just another name covering all entities in the MNE Group or there is something else to it?

The term “Constituent Entity” means

1. any separate business unit of an MNE Group that is included in the consolidated financial statements of the MNE Group for financial reporting purposes, or would be so included if equity interests of the Ultimate Parent Entity of the MNE Group were traded on a public securities exchange;

2. any such business unit that is, or would be, excluded from the MNE Group’s consolidated financial statements solely on size or materiality grounds; and

3. any permanent establishment of any separate business unit of the MNE Group included in (1) or (2) above provided the business unit prepares a separate financial statement for such permanent establishment for financial reporting, regulatory, tax reporting, or internal management control purposes.

A Constituent Entity does not, however, include a business unit that is an Excluded Entity, but talk about this next week!

Leadership principles for top managers at Big Multi Inc. 🏢

Rule #3 - Re-name your department

Your department or business unit is an extension of yourself. As a leader you are obviously smarter, more skilled, and overall better than any of your minions, but management will look at your unit as a whole. This means, you need to come up with a catchy name, so when CEO mentions your team, even he can sound more sophisticated! And when you are mentioned in the corporate communication, people will be impressed.

One of the common tricks is to use catchy corporate words such as technology, center of excellence, innovation hub, etc. But if you want to take the easy road, you can just add 2.0 to your current unit’s name. So Transfer Pricing becomes Transfer Pricing 2.0. It’s clear to everyone that International Tax Team 2.0 is at least twice as good as simple International Tax Team…

Another advantage of having a catchy name like Centre of Excellence is to convince the management that you need to involved in the next big thing in your company. Because who would not want to have excellence associated with the new project?

Tax Roast of the week

Coffee corner

Does the material or the shape of the cup matter?

Let's continue a bit with last week's topic. We agreed that size did matter. What else can be important? Does the material of the coffee cup matter? Yes, certainly. 

Some materials can keep the heat longer, some can get colder quicker. If you drink coffee from a cup made from glass you can enjoy not only the taste, the body and the smell but also you see the colour of the coffee and the thickness of the crema too. If you have a hand painted vintage coffee cup made of fine China, in your mind you can travel back to the era when it was made and can think of the coffee drinking habits of the mid or early twenty century (or even earlier depending the age of your precious vintage cup). When you drink your Irish coffee or lait russe seeing what you are drinking is part of the pleasure of having these drinks.

Does the shape of the cup matter? Absolutely, only the appropriate combination of the shape of the cup and the size will ensure that you can experience the full complexity of the aromes, the taste, the spices and savour of your morning coffee. This is the secret of how to enjoy a perfect coffee in the morning to get ready for the day. 

If in the morning you are in a rush, like many of us, just push the bottom of your espresso machine, use your regular morning cup and drink your morning brew, don't overthink or overdo it.

Your opinion matters more than you think!

We love creating this newsletter and we have a lot of fun doing it - otherwise we would not be here 🙂 But we want to make sure that everybody can learn about the latest update about international tax, discover something new about coffee and have fun with us! So, please tell us how you liked our newsletter!

We never say no to a good cup of coffee! So, if you loved the above, you can invite our crew for a coffee HERE.

DISCLAIMER: None of this is financial or tax advice. This newsletter is strictly educational and is not investment or tax advice or a solicitation to buy or sell any assets or to make any financial or tax decisions. Please be careful and do your own research.
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