Asia-Pacific
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Americas
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Europe
EU Advocate General addresses UK’s VAT exemption for cost-sharing groups
Francesca Amaddea, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the conclusions of Advocate General Juliane Kokott issued April 23 concerning a case before the European Court of Justice on the operation of the VAT exemption for cost sharing groups when a third country is involved . . .
Africa
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Africa
Countries still can’t agree on update to multinational group taxation rules, OECD official says
The 137 countries that make up the “Inclusive Framework on BEPS” are having a difficult time reaching agreement on an update to the global rules for allocating multinational group profits among nations, according to Pascal Saint-Amans, OECD Center for Tax Policy and Administration. Saint-Amans warned. . .
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Africa
Europe
Asia-Pacific
Americas
Europe
Italy’s financial transaction tax complies with EU law, court rules
Francesca Amaddeo a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, analyzes a long-awaited decision of the European Court of Justice, released on April 30, that concludes Italy’s financial transaction tax on derivatives of equity transactions is compatible with EU law . . .
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Americas
Europe
Asia-Pacific
Europe
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Europe
Italy addresses tax treatment of third-party payments under patent box rules
Gian Luca Nieddu, Partner Transfer Pricing & Tax Value Chain at Hager & Partners, Milan area, discusses Italian patent box guidance issued on April 24 that clarifies the tax treatment of contributions to research and development expenses made by a third party under a co-development and license agreement . . .
Digital Economy
Europe
Europe
Europe
New Poland transfer pricing risk assessment tool released in interactive format
Dr. Monika Laskowska of the Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish government’s newly launched an interactive version of its transfer pricing risk assessment tool which requires taxpayers to disclose to tax authorities much more information than required in the past . . .
Europe
Finland transfer pricing rules analyzed in landmark court rulings
Visa Randell, LL.M., M.Sc. (Econ.), Helsinki, discusses two important transfer pricing decisions of Finlands’ Supreme Administrative Court, released April 2; one concerns a sales company that incurred losses over multiple years and the other involves the tax authority’s attempt to restructure a transaction for transfer pricing purposes . . .
Europe
Africa
Asia-Pacific
Africa
COVID-19 and the future of Pillar one
Oliver Treidler, CEO, TP&C GmbH, Berlin, considers how the COVID-19 crisis will likely affect global negotiations to reform the taxation of multinational groups, noting that a delay could give transfer pricing practitioners time to formulate an alternative, updated, concept of value creation to replace Pillar one’s formulaic elements . . .
Asia-Pacific
Europe
Netherlands and Germany agree on cross-border worker taxation in light of COVID-19
Jian Cheng Ku, Rhys Bane, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam, analyze a competent authority agreement executed by the Netherlands and German governments addressing the application and interpretation of Article 14 (income from employment) of the Netherlands-Germany tax treaty in light of recent measures to curb COVID-19 . . .
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Asia-Pacific
New South Korea transfer pricing and diverted profits tax laws enter into effect
Jay Shim and Steve Minhoo Kim of Lee & Ko, South Korea, discuss important amendments to South Korea’s international tax and transfer pricing laws that became effective on January 1 including a Korean version of a diverted profits tax and new simplified transfer pricing rules for intra-group low value-adding services . . .
Americas
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