Europe
Luxembourg
Europe
Belgium
EU Commission calls out harmful tax practices in Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, Netherlands
The EU Commission took tentative steps toward reducing harmful tax competition among EU member countries today, publishing European Semester country reports that identify seven EU countries as potentially facilitating tax avoidance by multinationals. The Commission today also released a taxation paper detailing economic evidence that suggests that particular tax avoidance structures , , ,
Europe
Europe
Europe
Text of Luxembourg, Ukraine tax treaty protocol released
The text of the Luxembourg-Ukraine tax treaty protocol, signed September 30, has been released by Luxembourg’s tax administration. The treaty, which would amend the countries’ 1997 tax treaty, provides for a reduction in the . . .
Europe
Europe
Italian Supreme Court rejects Luxembourg company tax appeal, finds parent-subsidiary directive inapplicable
Gian Luca Nieddu of Hager & Partners, Milan area, discusses a recent Italian Supreme Court decision rejecting an Italian corporation’s request for reimbursement of withholding taxes paid on dividends distributed to its Luxembourg parent; the author argues that the opinion is based on faulty reasoning . . .
Europe
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Europe
Americas
Europe
Europe
Europe
Europe
Europe
Europe
Europe
EU State aid probe into tax rulings extends to group financing companies, TNMM use
The EU Commission on June 3 released a working paper identifying several categories of Member State transfer pricing rulings that raise potential State aid concerns because they sanction profit allocations. . .
Europe
EU state aid decisions on Starbucks and Fiat tax rulings challenged in court
As expected, the EU Commission will need to defend in court its contention that advance pricing agreements (APAs) granted to a Starbucks subsidiary by the Netherlands and to a Fiat subsidiary by Luxembourg . . .
Europe
Europe
Europe
Luxembourg law adapting corporate tax code to EU law contains gaps
Paloma Schwarz Martínez, a PhD Researcher at the University of Luxembourg, analyzes Luxembourg’s new law implementing changes made to the EU Parent-Subsidiary directive, noting that restrictions on hybrid mismatch arrangements and new antiabuse rules will not apply when non-EU companies are involved in a transaction.
Americas
Americas
Europe
EU Commission releases opening decision in State aid probe of Luxembourg tax rulings granted Engie
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 . . .
Europe
Luxembourg announces corporate tax rate cut
Luxembourg is planning to lower its corporate tax rate over the next two years, writes Paloma Schwarz Martínez, a PhD researcher at the University of Luxembourg. . . .
Europe
France/Luxembourg protocol taxing indirect real estate transfers to enter into effect in 2017
A protocol to the Luxembourg/France tax treaty, signed September 15, 2014, has been ratified by both jurisdictions and will enter effect on January 1, 2017, according to information . . .
Denmark
Cyprus
Europe
Africa
New Luxembourg/Senegal tax treaty includes clauses from UN model treaty
The Luxembourg Ministry of Finance today announced that Luxembourg and Senegal have signed a new tax treaty. The double tax avoidance agreement was signed by Pierre Gramegna, Luxembourg’s . . .
Africa
Ireland tax treaty update: agreements with Zambia, Germany, Luxembourg enter into force; pacts with Ethiopia, Pakistan ratified; new treaty with South Africa under negotiation
Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .
Africa
Luxembourg announces new tax treaty with Serbia; entry into force of protocols with Ireland, Mauritius, Lithuania and UAE; and law approving tax treaties with six other nations
The government of Luxembourg has announced that protocols signed with Ireland, Mauritius, Lithuania and United Arab Emirates entered into force on December 11 and . . .
Asia-Pacific
Singapore-Luxembourg tax treaty enters into force
The Inland Revenue Authority of Singapore has announced that the Luxembourg-Singapore tax treaty, signed . . .
Americas
US weighing changes to draft model tax treaty provisions, negotiating new treaty with Luxembourg
The US is considering changes to draft US Model Income Tax Convention provisions released last May, including several changes to provisions that deny tax treaty benefits to related party payments that are subject to a special tax regime (STR) . . .
Europe
The State Administration of International Tax Avoidance: Omari Y. Marian / SSRN →
Professor Omari Y. Marian of the University of California, Irvine School of Law analyzes the “Lux Leaks” tax rulings, concluding that the Luxembourg tax authority, in exchange for payment, purposefully created legal differences between the tax laws of source and residence jurisdictions for multinationals to exploit. See: SSRN.
Europe
Journalists publish 35 more leaked Luxembourg tax rulings on the Internet
The International Consortium of Investigative Journalists (ICIJ) on December 9 published on the Internet 35 more leaked Luxembourg private tax rulings. The documents originated from the big four accounting firms, as well as from smaller Luxembourg-based tax firms and law . . .
Belgium
EU committee publishes letters from 13 nations on tax ruling practices
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
