Europe
Ireland
Americas
Europe
Europe
Americas
Europe
Denmark
Europe
Europe
Europe
Irish tax authority introduces formal bilateral advance pricing agreement program
Irish Revenue has today released guidelines establishing a formal bilateral advance pricing agreement (APA) program to provide certainty for multinational corporation transfer pricing . . .
Europe
Europe
Europe
Europe
Americas
US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Europe
Ireland extends country-by-country filing deadlines
Ireland’s tax authority on November 24 announced that it will extend the deadline for filing country-by-country reports of multinationals for fiscal years ending in 2016. The deadline has been extended from December 31 to February 28, 2018, due to technical difficulties associated with the electronic filing system. Irish Tax and Customs . . .
Europe
Ireland’s tax treaty position on the OECD multilateral instrument
Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .
Americas
Americas
Asia-Pacific
Americas
Estonia
Ireland-Estonia treaty now exempts some royalty payments from tax
The tax treatment of royalty payments under the Ireland-Estonia tax treaty has been revised on account of the treaty’s most favored nation clause, Irish . . .
Digital Economy
Europe
Europe
Alan Heuston joins McCann FitzGerald
Alan Heuston, has joined McCann FitzGerald’s tax group a partner in the Dublin office, the firm . . .
Council of the EU
EU ministers unable to agree on multinational anti-tax avoidance rules, compromise plan offered
EU finance ministers at a meeting of the ECOFIN today failed to reach agreement on the EU Commission’s proposed anti-tax avoidance directive, though officials remained optimistic that a compromise agreement can . . .
Americas
Africa
Americas
Europe
Americas
Europe
Americas
Europe
Ireland eases process to claim withholding tax exemption for patent royalties paid for nonresident companies
Irish Tax and Customs has amended its tax guidance to make it easier for companies to an claim an exemption from withholding for . . .
Americas
US and Ireland commence tax treaty renegotiation: what could change
Steptoe & Johnson LLP partner, Amanda Varma, discusses the recent announcement that the US and Ireland are renegotiating their tax treaty, and identifies provisions in the existing US-Ireland tax treaty that the US will likely try to modify . . .
Americas
Americas
Ireland granted Apple illegal state aid through tax rulings sanctioning stateless income, EU says
The European Commission on August 30 announced it has concluded that Ireland granted Apple about €13 billion (USD 14.5 billion) in illegal state aid by issuing tax rulings to the company that inappropriately lowered its tax liability in 2003–2014. To restore fair competition, Apple must repay the aid to plus interest, the Commission said. The determination comes after a two year investigation . . .
More:
Apple CEO calls state aid decision “political crap”: Los Angeles Times→
Obama to address Apple decision at G20: AP→
Irish Cabinet agrees to appeal Apple decision: RTE News→
Asia-Pacific
Europe
