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United Kingdom
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Accounting
Europe
Europe
Electricité de France v. France: pricing of intercompany convertible and vanilla debt
New York City Economist Dr. J. Harold McClure analyzes the French Court of Appeal’s January 25 ruling in favor of the multinational in a somewhat involved intercompany financing pricing issue in a decision in case number 20VE00792; SAS Electricité de France International (SAS EDFI) is France’s largest electricity provider and owns the UK affiliate EDF Energy UK Ltd (EDFE).
Belarus
Europe
The EU maze for deducting final losses of a nonresident permanent establishment
Dragos Dancau, Ericsson, discusses the European Court of Justice’s March 10 publication of the opinion of Advocate General Collins in C-538/20 Finanzamt B v W AG; the case leaves questions the German referring court raised on how previous cases should be interpreted and shows the maze in analyzing the deduction of the final losses of a nonresident PE within the EU.
Europe
Europe
Americas
The Pillar Two model rules: a train wreck in the making
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
Europe
Europe
Europe
Africa
Asia-Pacific
Europe
Belgium
EU draft directive to tackle “shell entities”: ATAD III or the European Magnificent Seven-step approach
Geoffroy Galéa, Alain Thilmany, and Cassandre Guéry, Fieldfisher, discuss the European Commission’s 22 December 2021 publication of the ATAD III directive, which will increase the tax authorities’ attention to the international concept of substance; more than ever, it is crucial for multinational groups to . . .
Europe
Asia-Pacific
Americas
Americas
Accounting
Accounting
US finalizes tax rules for transition from interbank offered rates
The US Internal Revenue Service released final regulations on December 30 that provide that certain changes to debt instruments, derivative contracts, and other contracts to change the reference rate due to the discontinuation of the London Interbank Offered Rate (LIBOR) and other interbank offered rates will not result in a tax . . .
Europe
Americas
Americas
Asia-Pacific
Asia-Pacific
Americas
Europe
Europe
Accounting
Europe
Europe
Europe
Africa
Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal
Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .
Africa
Asia-Pacific
India intercompany financing: debt versus equity and the pricing of intercompany loans
New York City Economist Dr. J. Harold McClure discusses the Mumbai Income Tax Appellate Tribunal’s August 20 ruling against the Indian tax authority in Bennett Coleman & Co Ltd (As successor to Times Infotainment Media Limited) v. Deputy Commissioner of Income Tax, and analyzes the two questions . . .
Asia-Pacific
