Featured News

Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation

Late 2021, Finland implemented a regulation concerning taxation of reverse hybrid arrangements included in article 9a of ATAD2 directive (Council directive (EU) 2017/952 amending Directive 2016/1164). The new rules have been implemented in Section 8a of the Finnish act on taxation of cross-border hybrid arrangements (Hybrid Act) and have been applied for fiscal year 2022 onwards.

Featured News

Greek Guidance on Controlled Foreign Corporations

By virtue of Law 4607/2019 (published in the Greek Government Gazette Α’ 65/24-04-2019), certain provisions of the Council Directive 2016/1164/EU of July 12, 2016, have been embedded in the Greek legislation and namely in the Greek Income Tax Code (ITC) (article 66 of L.4172/2013).

Americas

Muddled goals, broad scope lead to unexpected costs of OECD tax agreement

Alex M. Parker, Capitol Counsel LLC, discusses why last year’s OECD-G20 global minimum tax agreement has revealed a scope much broader than most anticipated; provisions of the agreement, revealed in technical commentary released by the OECD in the past months, could affect everything from green energy incentives to affordable housing credits in the U.S.

Africa

Danish High Court rejects discretionary tax assessment in groundbreaking transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, analyzes the High Court of Eastern Denmark’s March 28 ruling that dealt another harsh blow to the Danish Ministry of Taxation in the largest-ever transfer pricing case in Danish history regarding a USD 1.5 billion increase of taxable income for the oil business previously owned by A.P. Møller Maersk (now by Total Energies EP).

Americas

Why Pillar Two should be abandoned

Allan Lanthier, a former advisor to the Canadian government, argues that when EU finance ministers next meet on April 5, they should abandon Pillar Two, which, he says, is a deeply flawed initiative that includes major changes on which countries had never previously agreed, including a new Domestic Minimum Top-Up tax and a significant rewrite of the Undertaxed Payment Rule.

Europe

Italy makes recent changes to cooperative compliance tax regime

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss two significant developments the Italian Revenue Agency made this month to its cooperative compliance regime, a forum allowing a taxpayer to prevent tax audits and to agree in advance with tax authorities regarding the tax treatment of specific uncertain transactions.

Europe

Transfer pricing in Poland – a `Runmageddon’ for tax compliance teams

Milena Kaniewska-Srodecka, CrossBorder Solutions, discusses the rapidly evolving transfer pricing landscape in Poland, which is now quite challenging for compliance teams to navigate; even as the tax law in this area seems to be becoming more simplified on the one hand, there are still areas of dispute on the other, some unexpected obstacles, and the increasing consequences for noncompliance.