International tax professional, Ninja-Antonia Reggelin, discusses a proposed German law currently under debate that would allow corporations to use losses following a change of shareholders . . .
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 . . .
Tax specialist, Ninja-Antonia Reggelin, discusses Monday’s German Parliament committee hearing on the proposed reform of the investment tax law, including measures to address tax avoidance in the German banking sector through dividend arbitrage. . .
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. . .
Konstantin Sakuth of Linklaters LLP, Munich, discusses a June 28 European Court of Justice decision which settled a long-running debate regarding the legality under EU State aid rules of Germany’s “restructuring clause,” which allows carryback of tax losses following some company restructurings . . .
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 . . .
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 . . .
Tax specialist, Ninja-Antonia Reggelin, reviews a new German circular providing comprehensive guidance on the allocation of profits between a business and a foreign permanent establishment . . .
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 . . .
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 . . .
Tax specialist, Ninja-Antonia Reggelin, discusses a proposed new German tax law to combat multinational profit shifting, which includes implementation of transfer pricing documentation and country-by-country reporting and exchange of tax rulings, as well as several other measures. . .
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 . . .
Martin Kreienbaum, Director General of International Taxation at the Federal Ministry of Finance, has been selected to chair the OECD Committee on Fiscal (CFA) affairs, the OECD. . .
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, . . .
Tax specialist, Ninja-Antonia Reggelin, discusses the state of play in Germany regarding a Commission proposal for public release of country-by-country reports on multinationals . . .
Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .
The European Court of Justice on December 17 ruled in Timac Agro Deutschland v.Finanzamt Sankt Augustin (C‑388/14) as . . .
Japan and Germany on December 17 signed a tax treaty, wholly amending the . . .
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