The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses Italy's January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
The governments of Japan and Latvia today signed a their first tax treaty, Japan's Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus signed a tax treaty on . . .
The Netherlands' Director of General Tax Administration, Dr. JAJ (Hans) Leijtens, has resigned his post, the Netherlands government . . .
See: The Guardian.
The new UK-Uruguay tax treaty has entered into effect, the UK's Foreign & Commonwealth Office announced . . .
EU law requires that a company be given the opportunity to challenge a tax information order issued to implement a tax exchange of information request on the grounds that the request lacks "forseeable relevance," Advocate . . .
Japan and Lithuania have agreed in principle to a tax treaty, Japan's Ministry of Finance . . .
Cyprus' Ministry of Finance on December 22 announced that it will issue a decree setting out the requirements for country-by-country reporting . . .
The European Commission today published a non-confidential version of its decision to open a State aid investigation into whether a tax rulings granted by Luxembourg to Engie, formally known as GDF Suez . . .
Cyprus' Ministry of Finance has announced a delay in the application of a 2010 protocol amendment to article 13 of the tax treaty between Russia and Cyprus concerning . . .
Berlin-based tax specialist Ninja-Antonia Reggelin discusses a draft German law published in late December by the finance ministry which is designed to counter harmful foreign country tax practices through the disallowance of tax deductions for royalty payments made to related companies. . .
France’s Constitutional Council on December 29 struck down France’s controversial diverted profits tax law, finding it unconstitutional, and also determined that changes to the financial transaction tax are constitutional, writes Davide Anghileri of the University of Lausanne, a contributing editor at MNE Tax . . .
US Treasury has announced on its website that a Model 1 FATCA intergovernmental agreement (IGA), a supplemental . . .
The Luxembourg government on December 27 published new tax guidance for intragroup financing transactions. The guidance . . .
Canada and Switzerland on December 23 exchanged notes for automatic exchange of information in tax . . .