Terence Wilhelm of CARA Société d’Avocats, France, discusses taxpayer opportunities that have arisen on account of a November 22 ruling of the Court of Justice of the European concerning the French withholding tax . . .
Ivan Dimitrov discusses important tax changes introduced in Bulgaria last week, including the country’s first-ever controlled foreign company (CFC) rules and revisions to the thin capitalization regime . . .
Konstantin Sakuth of Linklaters LLP, Munich, discusses The EU Joint Transfer Pricing Forum’s recent report on joint transfer pricing audits which sets out ten recommendations for EU governments that wish to undertake such an approach. . . .
Geoffroy Galéa, Laura Deroy, and Jasper Adriaensen of Deloitte, Belgium discuss a draft transfer pricing circular released by the Belgian tax authority on November 9 which addresses topics such as appropriate use of comparables, intra-group services, financial transactions, and intangibles . . .
The Swiss government on November 14 announced that it will end special taxpayer-favorable allocation rules for new principal companies and Swiss finance branches, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, . . .
Dominika Langenmayr, Professor of Economics at Catholic University of Eichstaett-Ingolstadt, discusses the German Council of Economic Experts’ November 7 report to the German government, focusing the council’s tax policy proposals regarding a minimum tax, digital tax, CCCTB, and patent box . . .
Jim Stewart of Trinity Business School, Trinity College, Dublin, discusses the likely effects on Ireland of recent moves in the EU and elsewhere to increase taxation of multinational firms in the digital sector . . .
Bulgarian tax practitioner, Ivan Dimitrov, discusses a draft law presented for public discussion on November 5 by the Bulgarian government that would require multinationals to prepare transfer pricing documentation . . .