Europe
Germany
Digital Economy
Europe
Europe
Europe
German limit on tax deduction for related-party royalty payments approved by cabinet
The German cabinet has approved a draft law limiting tax deductions for cross-border royalty payments to related parties, writes Berlin-based practitioner, Ninja-Antonia Reggelin . . .
Germany
OECD releases 28 comments to draft on tax treaty residence of pension funds
The OECD on April 6 released public comments to a discussion draft intended to clarify the tax treaty residence of pension funds. The discussion draft, part of follow-up work . . .
Europe
Europe
Americas
Canada to negotiate tax treaties with Germany and Switzerland
Canada’s Department of Finance on June 7 announced in separate releases that it will commence tax treaty negotiations with . . .
Europe
Austria
Europe
Europe
Council of the European Union
Europe
Europe
Africa
Europe
EU court to review German law denying withholding tax exemption for some dividends paid to foreign parents
The European Court of Justice has published a reference for a preliminary ruling in a case challenging a German law that denies relief from withholding tax on some distributions . . .
Europe
New Germany-Switzerland tax arbitration agreement provides legal certainty
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
Europe
Russia investigates IKEA Germany for tax fraud from stock sale of Russian subsidiary
Russia’s Investigation Committee has again launched a criminal probe alleging that IKEA’s German division committed tax fraud when it failed to pay taxes upon its sale of stock in a Russian . . .
Austria
Multinationals asked to critique tax dispute resolution processes in Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden
The OECD has today asked global businesses to assess the mutual agreement procedure (MAP) for resolving tax treaty disputes in Austria, France, Germany, Italy . . .
Europe
Council of the European Union
Europe
Europe
German related-party royalty proposal conflicts with BEPS agreement, OECD tax official says
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. . .
Europe
Europe
Europe
Americas
EU finance ministers blast US international tax reform proposals
Finance ministers from Italy, Germany, France, the UK, and Spain have written to US Treasury Secretary Steven Mnuchin warning that provisions in the US tax reform bill contravene the US’s tax treaty and World Trade Organizations (WTO) obligations as well as international agreements reached under the OECD/G20 base erosion profit shifting (BEPS) plan. The ministers – Italy’s Pier Carlo Padoan, Germany’s . . .
Austria
EU court resolves tax treaty dispute between Germany, Austria regarding financial instrument
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. . .
Europe
Europe
Europe
Germany proposes tax deduction limits on royalties paid to related companies
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. . .
Asia-Pacific
Australia-Germany tax treaty enters into force
A tax treaty signed between Australia and Germany entered into force on December 7, Australia’s . . .
Europe
Europe
Europe
Americas
Asia-Pacific
Japan’s tax treaty with Germany, protocol with India, to enter into force
Japan’s Ministry of Finance today announced that two tax agreements will enter into force: a tax treaty with Germany and a protocol to a tax treaty with India. Notifications . . .
