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Luxembourg

Cyprus

Russia seeks to update Netherlands, Cyprus, Malta, Luxembourg tax treaty to add 15 percent withholding tax on dividends and interest: Mohammad Ali / UrduPoint→

August 10, 2020
Americas

Whirlpool’s maquiladora: the Mexican transfer pricing perspective

June 3, 2020

Dr. Harold McClure, a New York economist, discusses transfer pricing issues with respect to Whirlpool’s Mexico affiliate, which conducted toll manufacturing operations on behalf of a Luxembourg affiliate, as described in the recent Tax Court case, Whirlpool Financial Corporation v. Comr. . . .

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Europe

Luxembourg introduces transfer pricing documentation requirement for controlled foreign company compliance

April 8, 2020

Danny Beeton of Arendt & Medernach, Luxembourg and London, discusses a Luxembourg Tax Administration circular letter which sets out their detailed view of how the Luxembourg tax law applies to controlled foreign companies . . .

Europe

Luxembourg to extend tax payment deadlines in response to COVID-19 pandemic: The Luxembourg Government→

March 20, 2020
Europe

EU General Court to this week hear Amazon challenge to EU Commission finding’s that Luxembourg tax ruling granted State aid: Foo Yun Chee / Reuters→

March 4, 2020
Europe

Luxembourg enacts tax laws implementing 2020 budget proposals

January 8, 2020

Danny Beeton, Of Counsel, Arendt & Medernach, Luxembourg and London, discusses new tax laws adopted by Luxembourg on December 20 that affect multinationals . . .

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

No Picture
Belgium

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Europe

Luxembourg 2020 Budget requires all older tax rulings to expire

October 16, 2019

Danny Beeton, Of Counsel at Arendt & Medernach, Luxembourg and London discusses Luxembourg’s Budget Bill, published on October 14. . .

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

September 24, 2019

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Americas

US-Luxembourg tax treaty protocol enters into force

September 9, 2019

A new protocol to the US-Luxembourg treaty entered into force . . .

Europe

Luxembourg: bill submitted to implement anti-tax avoidance provisions  

August 29, 2019

Danny Beeton, of counsel to Arendt & Medernach in Luxembourg and London, discusses Luxembourg’s implementation of the intra-EU hybrid mismatches rules . . .

Americas

US Senate ratifies protocols to tax treaties with Japan, Switzerland, Luxembourg

July 17, 2019

The US Senate today ratified protocols to the US’s tax treaties with Japan, Switzerland, and Luxembourg. This follows the Senate ratification on . . .

Americas

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

August 17, 2019

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary to . . .

Asia-Pacific

MLI amendments to Singapore-Luxembourg tax treaty enter into effect

August 2, 2019

The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as . . .

Europe

Luxembourg updates filing procedure for CbC reporting: Bloomberg Tax→

July 25, 2019
Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Europe

Danny Beeton joins Arendt & Medernach’s transfer pricing practice

May 23, 2018

Arendt & Medernach has announced that transfer pricing specialist Danny Beeton has joined the firm working in both London and Luxembourg. Beeton is formerly with Duff and Phelps, London. His role at . . .

Africa

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

October 26, 2018

African countries that signed tax treaties with Mauritius and other nations considered to be “investment hubs” did . . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

No Picture
Americas

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Europe

Commission publishes opening decision in Huhtamäki state aid probe

May 7, 2019

The EU Commission on May 3 published . . .

Europe

Bortolotti to join Dentons Luxembourg as a transfer pricing partner

July 19, 2017

Dentons today announced that Cristiano Bortolotti will join the firm as a transfer pricing partner in the firm’s Luxembourg office. Bortolotti will also develop and assist more broadly the tax practice . . .

Cyprus

Luxembourg, Cyprus tax treaty published

June 8, 2017

Luxembourg’s tax administration has released on its website the text of a tax treaty and protocol signed by the Luxembourg. . .

Cyprus

Luxembourg, Cyprus sign tax treaty

May 8, 2017

Luxembourg and Cyprus have signed a tax treaty, Luxembourg’s Ministry of Finance announced today. The agreement. . .

Europe

Luxembourg transfer pricing bill would adopt some BEPS changes

October 28, 2016

Dr. Paloma Schwarz Martínez, University of Luxembourg, discusses a new bill under consideration by Parliament that would incorporate some of the BEPS transfer pricing changes into Luxembourg law . . . 

Europe

Luxembourg to contest Amazon State aid decision in EU court

December 15, 2017

The Luxembourg government today announced that it will appeal in General Court a European Commission decision that concluded that Luxembourg granted illegal State aid to Amazon’s Luxembourg subsidiary through a . . .

Europe

New Luxembourg transfer pricing rules may require documentation revision: KPMG Luxembourg→

March 2, 2017

See: KPMG Luxembourg.

Germany

OECD releases 28 comments to draft on tax treaty residence of pension funds

April 6, 2016

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 . . .

Africa

Twenty nations’ tax laws may aid multinational profit shifting, OECD report says

October 17, 2017

Twenty countries have tax laws that may be considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .

Asia-Pacific

Luxembourg, Uzbekistan sign tax treaty protocol

September 20, 2017

Luxembourg and Uzbekistan government officials have signed a tax treaty protocol, Luxembourg’s Ministry of Finance has announced. The protocol, signed September 18, would . . .

No Picture
Council of the European Union

Luxembourg’s Juncker blocked EU code of conduct group anti-tax avoidance measures, leaks show: Simon Bowers / The Guardian→

January 4, 2017

See: The Guardian. More: Luxemburger Wort, RT.

Africa

Turkey’s IP tax regime is harmful; new Singapore, Luxembourg, Lithuania, Slovakia laws meet standards, OECD report concludes

May 20, 2018

Turkey’s technology development zone tax regime is harmful to the tax base of other countries while new Singapore, Luxembourg, Lithuania, and Slovakia tax laws favoring intellectual property (IP) are not, a May 17 report prepared by the OECD Forum on Harmful . . .

Europe

Luxembourg will not immediately oppose EU equalization tax proposal: Luxemburger Wort→

September 14, 2017
Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Posts navigation

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RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
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  • New CbC Reporting Requirements to Apply in Kenya
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  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
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  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
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  • The Evolution of Transfer Pricing in Saudi Arabia
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  • The Functional Analysis—What You Need to Know
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  • How International Organizations are Changing Transfer Pricing Compliance
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Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
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Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
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Trending Now

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  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.