Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy's patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .
JP Canavan discusses the EU Court of Justice's highly anticipated decision in the Euro Park Service case, which further defines the limits of EU Member States’ ability to restrict tax deferral benefits on mergers, reorganizations, and similar transactions . . .
Davide Anghileri of the University of Lausanne discusses Italy's new country-by-country reporting requirements for large multinationals . . .
Switzerland's parliament, on March 10, approved a withholding tax exemption for intragroup interest payments, writes Davide Anghileri of the University of Lausanne. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP's destination-based cash flow proposal to partners and partnerships . . . .
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
Davide Anghileri of the University of Lausanne discusses a March 7 European Court of Justice ruling concluding that the EU VAT directive is valid under EU law even though it excludes electronically-supplied digital books, newspapers, and periodicals from a reduced rate of VAT . . .
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
Julian Feiner of Dentons, London, discusses the tax proposals in the UK budget, delivered today, which include proposed revisions to interest deductibility, loss relief, and hybrid mismatch rules . . .
The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .
JP Canavan discusses a proposed law, advanced by Australian government on February 16, which would overhaul the goods and services tax (GST) regime in relation to the importation of low value goods by consumers. . .
The New Zealand government on March 3 released a slew of tax proposals in three consultation documents all aimed at preventing tax avoidance . . .
Switzerland's Federal Department of Finance today announced its new "Tax Proposal 17" initiative to reform the Swiss corporate tax code, writes Davide Anghileri of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy's Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump's executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
Ashish Sodhani and Ameya Mithe of Nishith Desai Associates provide a comprehensive analysis of India's new guidelines for determining a foreign company’s place of effective management . . .
JP Canavan discusses newly released draft instructions to US Form 8975, which include information on early country-by-country reporting for US-parented MNEs and on how to report 'stateless' constituent entities . . . . . .
Dr. E. Brincker of Cliffe Dekker Hofmeyr, Johannesburg, discusses international tax proposals in the South Africa budget, delivered February 22, that will affect multinational corporations . . .