Americas
France
Americas
Digital Economy
Americas
Europe
France’s rules for taxing dividends from nonresident subsidiaries violate EU law, Commission says
The European Commission has today charged that France’s scheme for taxing of dividends from nonresident subsidiaries is discriminatory, and has asked France . . .
Digital Economy
Americas
Digital Economy
Europe
EU States must permit court challenge to tax information exchange request order, CJEU rules
EU states must allow a court challenge to the legality of an information order issued to implement a tax-related exchange of information request on the grounds that the request lacks “foreseeable relevance,” the Court of Justice. . .
Europe
Europe
Germany, France making progress on EU-wide corporate tax system
Konstantin Sakuth of Linklaters LLP, Munich, provides an update of Germany and France’s plan to jointly develop a common corporate tax base for Europe, noting June 5 comments made by Germany’s Martin Kreienbaum at the OECD Tax Conference in Washington and a May 31 German government announcement on the topic . . .
Europe
Americas
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
Europe
Americas
Europe
France’s diverted profits tax ruled unconstitutional
France’s Constitutional Council on December 29 struck down France’s controversial diverted profits tax law, finding it unconstitutional, and also determined that changes to the financial transaction tax are constitutional, writes Davide Anghileri of the University of Lausanne, a contributing editor at MNE Tax . . .
Europe
Americas
Europe
Europe
Europe
Digital Economy
Featured News
Europe
Europe
Asia-Pacific
Taiwan offers VAT refund to some foreign enterprises without fixed place of business
Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . .
Europe
Court voids French law denying withholding tax exemption for dividends paid outside EU
Davide Anghileri of the University of Lausanne discusses an EU Court of Justice ruling, delivered September 7, which concludes that France violated EU law when it applied a general antiabuse rule to deny a withholding tax exemption for dividends distributed by a resident subsidiary to a company controlled by a resident of a non-EU State . . .
Europe
Europe
Africa
Digital Economy
Europe
Jacques Mestoudjian joins Eversheds’ Paris office
Jacques Mestoudjian has joined Eversheds as a partner in its Paris office . . .
Austria
Austria
EU finance ministers split on public release of multinational corporation tax data
Dutch finance minister and president of the Eurogroup, Jeroen Dijsselbloem, expressed support for a proposal that would mandate public release of country-by-country tax data on multinationals, while finance ministers from Malta, Belgium, and Austria . . .
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Africa
Europe
Europe
Italy’s Supreme Court rules French holding company has sufficient substance for tax purposes
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Europe
France: public county-by-country reporting declared unconstitutional
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
