The European Court of Justice (ECJ), in a ruling released September 12, has concluded that the ECJ has jurisdiction to resolve a dispute between Member States which relates to the subject matter of the Treaties of the European Union if the dispute is submitted under a special agreement between the parties, writes Davide Anghileri of the University of Lausanne. . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
International tax attorney Ninja-Antonia Reggelin discusses German guidance issued May 17 detailing the limited tax liability and source taxation of cross-border transfers of software and databases . . .
A German court has struck down portions of a controversial law that denies tax loss carryforwards following a change of shareholders, ruling that the provisions are unconstitutional, writes international tax practitioner Ninja-Antonia Reggelin . . .
Tax professional Ninja-Antonia Reggelin discusses a German parliamentary hearing, held Wednesday, where tax experts provided their views on a controversial proposal to deny tax deductions for some royalty payments made by multinationals to related companies. . .
The European Court of Justice has published a reference for an Austrian case (Case C-648/15) concerning whether Austria or Germany can tax profit-participation certificates (Genussscheine). Austria claims that the Court should hold that . . .
Berlin-based tax specialist Ninja-Antonia Reggelin discusses a draft German law published in late December by the finance ministry which is designed to counter harmful foreign country tax practices through the disallowance of tax deductions for royalty payments made to related companies. . .