Featured News

Europe

Luxembourg 2020 Budget requires all older tax rulings to expire

October 16, 2019

Danny Beeton, Of Counsel at Arendt & Medernach, Luxembourg and London discusses Luxembourg’s Budget Bill, published on October 14. . .

Africa

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

October 10, 2019

Davide Anghileri of the University of Lausanne, Switzerland, resolutions relating to taxation adopted by the of the EU Council today . . .

Digital Economy

OECD’s proposed “unified approach” would give market countries greater taxing rights over large multinationals that sell to consumers

October 10, 2019

In an effort to expedite agreement between nations on an update to the international tax rules to account for new digital business models, the OECD secretariat on October 9 proposed a compromise plan for allocating multinational . . .

Europe

Ireland Budget 2020 released

October 10, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Budget 2020 measures, released by the government on October 8 . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Africa

EU Code of Conduct Group proposes changes to tax blacklist for seven countries including Switzerland, UAE, Mauritius

October 8, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses October 4 EU Code of Conduct Group (Business Taxation) recommendations for amendments to the EU list of non-cooperative tax jurisdictions . . .

Americas

Argentina issues burdensome draft transfer pricing guidance for public comment

October 7, 2019

Elisa Kaminsky, a senior associate at BaseFirma, Miami, discusses an October 2 public consultation on new Argentina transfer pricing guidance which includes significant and burdensome new requirements . . .

Europe

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty

October 7, 2019

Leopoldo Parada of the University of Turin, Italy, writes about the implications of the EU General Court’s decsion in the Fiat and Starbucks state aid cases . . .

Americas

Return on assets (ROA) is an unreliable profit indicator

October 2, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that selection of “return on assets” as a profit indicator in transfer pricing can lead to intractable controversy because the term is ill-defined whereas operating profit margin and operating profit markup are more reliable . . .

Americas

Canada’s liberal party proposes three percent digital services tax on advertising, intermediation

October 2, 2019

Canadian Prime Minister Justin Trudeau’s Liberal Party has proposed in its reelection platform . . .

Draft “toolkit” aims to help developing countries with transfer pricing documentation

October 2, 2019

The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund, OECD, United Nations, and World Bank Group – on September 27 released a draft “toolkit” aimed at helping developing nations design transfer pricing . . .

Americas

New IRS rules addresses unintended effects of Sec. 958(b)(4) repeal on US-owned foreign stock

October 1, 2019

The US IRS today issued guidance designed to give relief to US persons that own stock in certain foreign corporations. The new guidance was prompted by a need to address unintended consequences of the . . .

Europe

Italian Revenue clarifies new reporting option for patent box tax benefit

October 1, 2019

Gian Luca Nieddu, Head of Transfer Pricing and Tax Value Chain at Hager & Partners, Milan area, writes about Italy’s September 9 clarifications to the patent box regime . . .

Europe

Germany publishes revised tax law requiring disclosure of cross-border transactions

October 1, 2019

German tax practitioner Ninja-Antonia Reggelin notes that a draft German law, released September 27, requiring advisors or their clients to disclose information on cross-border transactions and structures to the national tax authorities differs from earlier versions . . .

Asia-Pacific

Turkey: new tax audit wave focuses on nonresident digital companies

October 1, 2019

Ramazan Biçer, a partner with Centrum, Istanbul, discusses a new wave of tax audits being undertaken in Turkey scrutinizing the taxation of nonresident taxpayers engaged in the digital economy . . .

Asia-Pacific

Indian court rules Hitachi Singapore’s liaison office is a permanent establishment

September 26, 2019

Chartered Accountants Deepak Manoharan and Nathansha Dilip discuss the Hitachi case, a landmark ruling where the Delhi bench of the Income Tax Appellate Tribunal concludes that a liaison office could be treated as a permanent establishment of a foreign entity in India . . .

Europe

Denmark tax bill clarifies timing rules for transfer pricing documentation

September 25, 2019

Peter S. Andersen, a transfer pricing partner with Questro International, discusses Denmark’s proposed new requirements for transfer pricing documentation which were included in a Denmark Ministry of Taxation draft bill published on September 12 . . .

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

September 24, 2019

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Digital Economy

Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London

September 24, 2019

Arnas Laurynas, Managing Director of Quantera Global, London, discusses some of the highlights of IFA Congress 2019, held September 8–12 in London, which brought together leading international tax and transfer pricing experts from around the world . . .

Americas

Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico

September 24, 2019

Fernando Juarez Hernandez, an international tax attorney with Cacheaux, Cavazos & Newton, LLP, discusses Mexico 2020 tax reform, introduced September 8, which proposes far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code . . .

Asia-Pacific

India fires bazooka to lift economy, slashing corporate tax rates and enacting other tax relief

September 23, 2019

Rajesh Gandhi and Gaurav Chandak of Deloitte Haskins & Sells LLP, Mumbai, discuss the Indian government’s surprise announcement on Friday of a significant reduction in the corporate tax rates which became effective immediately . . .

Europe

The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises

September 18, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s 2020 budget and tax plan, presented September 17, which proposes modifications to the taxation of multinational firms . . .

Europe

Netherlands foreign investment fund tax regime may breach EU law, advocate general says

September 17, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Netherlands, discuss a September 5 opinion of the European Court of Justice Advocate General in a dispute involving the availability of Dutch dividend withholding tax refunds for foreign investment funds . . .

Asia-Pacific

India specifies transfer pricing arm’s length tolerance range

September 17, 2019

Gaurav Jain, a chartered accountant, and Priya Bhutani discuss Indian guidance released September 13 addressing the transfer pricing arm’s length tolerance range for wholesale trading and other activities . . .

Europe

German finance minister endorses public country-by-country reporting of MNE tax information

September 17, 2019

German tax practitioner Ninja-Antonia Reggelin discusses the changing German position on public release of country-by-country reporting data . . .

Unresolved cross-border tax disputes continue to rise, OECD stats show

September 16, 2019

Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax . . .

Belgium

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

September 16, 2019

The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian . . .

Asia-Pacific

Australia: Glencore’s ‘big win’ for taxpayers on transfer pricing

September 12, 2019

Ruth Butter and Stefan Sunde at TP EQuilibrium AustralAsia discuss Glencore’s recent win in a transfer pricing dispute before the Federal Court of Australia . . .

Digital Economy

Saint Amans provides update on digital tax reform effort

September 12, 2019

The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing . . .

Europe

Switzerland: Zurich approves cantonal tax reform

September 11, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses tax reform provisions approved by the canton Zurich’s tax on September 1 . . .

Europe

Ireland proposes sweeping changes to transfer pricing laws

September 4, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses the Irish government’s proposed amendments the transfer pricing rules, released earlier this week . . .

Asia-Pacific

Australia provides arm’s length debt test guidance

September 3, 2019

Leslie Prescott-Haar and Stefan Sunde at TP EQuilibrium AustralAsia discuss the Australian Tax Office’s August 28 draft guidance on applying the arm’s length debt test for thin capitalization purposes . . .

Report assesses 116 nations’ implementation of country-by-country reporting

September 3, 2019

The OECD today released a peer review report judging whether 116 countries and their tax administrations have met . . .

Asia-Pacific

First Look: Glencore wins Australian transfer pricing case

September 3, 2019

Glencore won an AUS $92m (USD 62m) transfer pricing dispute with the . . .

Americas

Mexico proposes new rules to tax highly digitalized businesses

September 2, 2019

Fernando Juarez Hernandez, a tax attorney in Mexico City, discusses a Mexican bill introduced to Congress August 21 that would tax digital platforms . . .

Asia-Pacific

Georgia: a low-tax European country with much to offer investors

September 2, 2019

Gela Barshovi, Tax Advisor and Managing Partner at TPsolution, Tbilisi, Georgia, discusses the tax and regulatory advantages of conducting business in Georgia . . .

Europe

Luxembourg: bill submitted to implement anti-tax avoidance provisions

August 29, 2019

Danny Beeton, of counsel to Arendt & Medernach in Luxembourg and London, discusses Luxembourg’s implementation of the intra-EU hybrid mismatches rules . . .

Americas

US, France reach deal on digital services tax

August 26, 2019

French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires . .

Africa

Zimbabwe proposes amendments to thin capitalization rules

August 26, 2019

Walker Nyachowe, Managing Director of Walker Consulting Services, discusses Zimbabwe’s Minister of Finance Economic Development’s 2019 Mid-Term Fiscal Policy Review Statement, delivered August 1, which includes proposed amendments the thin capitalization rules . . .

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

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