France
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.
Electricité de France v. France: pricing of intercompany convertible and vanilla debt
New York City Economist Dr. J. Harold McClure analyzes the French Court of Appeal’s January 25 ruling in favor of the multinational in a somewhat involved intercompany financing pricing issue in a decision in case number 20VE00792; SAS Electricité de France International (SAS EDFI) is France’s largest electricity provider and owns the UK affiliate EDF Energy UK Ltd (EDFE).
The Pillar Two model rules: a train wreck in the making
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
Swiss international tax update addresses OECD deal, treaties, MAP
Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .
Belgium and France sign new tax treaty
Moïse Gnakouri, Catholic University of Louvain, discusses the new tax treaty Belgium and France signed on November 9, which complies with new international standards, and includes several changes, including the taxation of capital gains on the sale of shares of companies with assets consisting . . .