Europe

EU Presidency to argue MNE anti-tax avoidance measures increase uncertainty, reduce investment: Francesco Guarascio & Jan Strupczewski / Daily Mail Online→

April 7, 2017

Europe

“LuxLeaks” tax whistleblowers’s sentences reduced: Pierre Sorlut / France 24→

March 15, 2017

See: France 24. More: EU Observer, Deutsche Welle, ABC News.

Americas

Austrian holding companies without substantial economic activities are ‘privileged tax regimes,’ Brazil concludes: KPMG→

January 18, 2017

See: KPMG.

Americas

US, Belgium FATCA agreement enters into force

January 3, 2017

US Treasury has announced on its website that a Model 1 FATCA intergovernmental agreement (IGA), a supplemental . . .

Europe

French Parliament approves bill providing for diverted profits tax: EY→

December 23, 2016

See: EY.

UK agrees to terminate Swiss withholding tax arrangement

November 15, 2016

Switzerland and the UK will terminate their 2013 withholding tax agreement as of January 1, 2017, under a deal struck . . .

Europe

Alan Heuston joins McCann FitzGerald

October 6, 2016

Alan Heuston, has joined McCann FitzGerald’s tax group a partner in the Dublin office, the firm . . .

Europe

EU expected to open a new state aid tax ruling probe involving Luxembourg, sources say: Suzanne Lynch / Irish Times→

September 5, 2016

See: Irish Times.

EU ministers unable to agree on multinational anti-tax avoidance rules, compromise plan offered

May 25, 2016

EU finance ministers at a meeting of the ECOFIN today failed to reach agreement on the EU Commission’s proposed anti-tax avoidance directive, though officials remained optimistic that a compromise agreement can . . .

Asia-Pacific

Tax treaty between Cyprus and Bahrain enters into force

May 11, 2016

A tax treaty between Cyprus and Bahrain entered in to force on April 26, Cyprus’s Ministry of Finance . . .

Americas

Allergan, Pfizer abandon merger following new US tax regs on “serial” inversions: Don Lee / Los Angeles Times→

April 6, 2016

See: Los Angeles Times. More: Reuters. Related: MNE Tax.

Algeria

Spain appeals EU General Court’s finding of State aid in goodwill tax scheme

March 28, 2019

Spain has appealed to the Court of Justice of the European Union seeking to overturn judgments . . .

Europe

Russian VAT on foreign companies providing B2B electronic services kicks in: TASS→

January 2, 2019

Europe

France’s 2019 draft Finance Bill adds new rules for patent boxes, interest deductions, tax consolidation

October 2, 2018

Terence Wilhelm of CARA Avocats, Lyon, France, discusses the French government’s just-released finance bill, focusing on tax proposals of particular interest to MNEs . . .

Europe

EU court invalidates German law taxing dividends from non-EU subsidiaries

September 26, 2018

Davide Anghileri of the University of Lausanne discusses a September 20 decision of the ECJ invalidating a German law that introduced less favorable business tax treatment for dividends received from subsidiaries located in non-EU countries . . .

Europe

Dutch 2019 budget released

September 18, 2018

The 2019 Dutch Budget was released today, proposing changes to the dividend withholding tax and implementing aspects of the EU Anti-Tax Avoidance Directive, among other things. An MNE Tax expert analysis will be published shortly . . .

Americas

OECD reports assess tax dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

August 30, 2018

Peer review reports assessing the cross-border tax dispute resolution process in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal prepared by the “Inclusive Framework on BEPS,” . . .

Africa

CIAT transfer pricing audit guide to aid member countries’ tax administrations

August 22, 2018

Robert Feinschreiber of Charles River Associates and Margaret Kent of TransferPricingConsortium.com write that CIAT is developing an updated and enhanced transfer pricing audit guide for use by the tax administrations of its member countries . . .

European Economic and Social Committee reports on efforts to tax digital economy

July 31, 2018

European Economic and Social Committee, in a report released July 30, recommended that the EU analyze the effect of any interim measures to tax the digital companies on investments, start-ups . . .

Europe

German CFC rules comply with EU law thanks to standstill clause, ECJ Advocate General says

June 20, 2018

German practitioner Ninja-Antonia Reggelin discusses a June 5 opinion of the EU Advocate general in a case pending before the ECJ that calls into question the legality Germany’s controlled foreign company rules . . .

Africa

Irish Revenue updates frequently-asked-questions on country-by-country reporting for multinationals

May 6, 2018

Irish Revenue has added new Tax and Duty Manual, Part 38-03-21 providing answers to frequently asked questions on Ireland’s laws and regulations applicable to large multinationals on country-by-country . . .

Europe

UK financial regulator considers prohibiting accounting firms that do audit work from consulting: Madison Marriage / Financial Times→

March 27, 2018

Europe

French court in Valueclick rules that Irish company’s French employees did not create permanent establishment: KPMG→

March 14, 2018

Europe

Ukraine updates transfer pricing rules, adds APA regime: DLA Piper→

January 31, 2018

Europe

Luxembourg court overturns conviction of “Lux Leaks” whistleblower Antoine Deltour, upholds conviction of Raphaël Halet: BBC News→

January 11, 2018

Europe

Italy introduces web tax, updates PE definitions

January 7, 2018

Davide Anghileri of the University of Lausanne discusses Italy’s new web tax and update to permanent establishment definitions . . .

Americas

OECD requests feedback on tax treaty dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

November 24, 2017

The OECD on November 24 asked for taxpayer input to conduct stage 1 peer reviews of the tax dispute resolution processes in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal. Taxpayers are . . .

Europe

Coffey defends Irish proposal to tax multinational firms by limiting capital allowance offset to intangible asset revenue: Seamus Coffey / Irish Times→

November 15, 2017

Americas

US, Lithuania sign country-by-country report exchange agreement

September 14, 2017

The US and Lithuania have agreed to annually exchange country-by-country reports on the tax affairs of large multinational businesses, the IRS reported. . .

Europe

International tax lawyer Alex Tostevin joins Dentons’ London office

July 3, 2017

Dentons on July 3 announced that Alex Tostevin has joined the firm’s London office as a partner in London. Tostevin advises UK and international clients on all areas of tax. His clients include sovereign wealth funds, private . . .

EU preparing law targeting lawyers, accountants that assist with tax avoidance: Jennifer Rankin / The Guardian→

May 31, 2017

Europe

Italy clarifies tax credit for R&D activities

May 8, 2017

The Italian Revenue Agency has released a new circular clarifying aspects of Italy’s tax credit regime for research and development activities notes Davide Anghileri of the University of Lausanne . . .

Americas

Professor identifies the stakeholders in Apple State aid tax controversy: J. Clifton Fleming Jr. / SSRN→

March 15, 2017

See: SSRN.

Asia-Pacific

India-Belgium tax treaty protocol signed

March 9, 2017

India and Belgium today signed a protocol to their existing tax treaty to broaden the scope of exchange of tax information between the countries, India’s . . .

South Africa, Switzerland agree to automatic exchange of information

November 26, 2016

On 24 November, Switzerland signed joint declarations on the introduction of automatic exchange of information (AEOI) in tax matters with South Africa, writes Davide Anghileri of the University of Lausanne . . .

Americas

Brazil, Guernsey, Jersey, Isle of Man, Latvia sign agreement for exchange of tax reports on multinationals

October 24, 2016

Brazil, Guernsey, Jersey, the Isle of Man, and Latvia have signed a multilateral agreement which sets out the parameters for the automatic exchange between tax administrations of country-by-country tax reports on . . .

Europe

Starbucks State aid decision published by EU Commission

June 27, 2016

The EU Commission today published a non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Starbucks subsidiary by the Netherlands is illegal State aid and ordering recovery of the . . .

Europe

UK consults on use of corporate tax losses: EY→

May 31, 2016

See: EY.

Europe

Luxembourg adopts exchange of information on cross-border rulings: EY→

May 6, 2016

See: EY

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
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