The UK's HM Revenue and Customs on May 21 issued guidance on the treatment of holding companies and treasury companies under FATCA, the multilateral competent authority agreement implementing the common reporting standard, and the . . .
Irish Tax and Customs, on April 16th, released guidance on the tax treatment of investments in exchange traded funds. According to a government . . .
Portugal, on March 5, ratified at tax treaty Georgia, signed December 12, 2012. An English-language version of the treaty is available . . .
Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .
The Irish government on January 29 released guidance clarifying a law added in the Finance Act 2013 that provides for an additional foreign tax credit for foreign dividends received . . .
An advance pricing agreement (APA) issued to Amazon by the Luxembourg tax authorities setting the price of intra-group royalties seems to be designed to ensure a predictable level of profit to Amazon’s Luxembourg operations rather than to achieve an arm’s length result, and thus appears likely to be state aid, the European Commission . . .
Russian President Vladimir Putin on December 1 signed addendums to the country’s tax code providing enhanced tax benefits to residents of the free economic zone in Crimea, Russian news agency TASS has reported. Under the new provisions . . .
Jersey and Romania on December 1 signed a tax information exchange agreement (TIEA) at the Romanian Embassy in London, the government of Jersey has . . .
The European Commission has concluded that a Spanish tax scheme benefiting companies that acquire foreign shareholdings is incompatible with EU state aid rules . . .
Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced. Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
The requirements for the entry into force of the treaty between Luxembourg and the Czech Republic, signed March 5, 2013, were met on July 31 and the treaty entered into force as of that date, the Luxembourg tax authority has announced. Release (in French), A Memorial - No. 162 of August 14, page A 2501 (in French)
Albania's Ministry of Finance has issued guidance on new Albanian transfer pricing laws which became effective in June, according to a July 25 report by EY. For a detailed discussion of the new guidance, see EY.
Ireland's Department of Finance, on May 27, announced a consultation to consider international stakeholder's views on how Ireland's tax system should respond to the OECD's base erosion and profit shifting (BEPS) initiative. "Ireland remains 100% committed to the 12.5% corporation tax rate. . . .
See also, Why Ireland should address corporate tax residency rules before we’re forced to, By Feargal O'Rourke, The Irish Times