Malta–MNE Tax

Estonia

EU finance ministers fail to unanimously agree on proposed Pillar Two directive; the date on which member states would make it effective had been moved from Jan. 2023 to Dec. 2023 in compromise text; the UTPR is delayed to Dec. 2024 under this compromise; Estonia, Malta, Poland, and Sweden still have reservations; will try again Apr. 5: János Ammann / EURACTIV→

March 15, 2022

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Africa

Swiss international tax update addresses OECD deal, treaties, MAP

January 12, 2022

Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .

Europe

Malta consults on draft transfer pricing rules, APA program

December 29, 2021

The Maltese government on December 20 opened a consultation seeking feedback on draft transfer pricing rules with the intention of using the feedback to craft final transfer pricing rules to be published in late 2022 and then apply the rules to tax years beginning in . . .

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Europe

‘Single malt’ multinational tax avoidance techniques still being exploited via Ireland-Malta intercompany transfers despite 2019 agreement between the countries to end the practice, charity claims: Pat Leahy / The Irish Times→

September 15, 2021

Americas

European banks’ tax haven use persists but varies widely, study finds

September 7, 2021

Large European banks report an average of 20% of their profits in tax havens, but some report more than half of their profits in such jurisdictions while others report none, according to a September 6 report from the EU Tax Observatory . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Europe

Malta issues guidelines on DAC 6 disclosures of crossborder arrangements: Office of the Commissioner for Revenue→

January 5, 2021

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Europe

Malta releases DAC6 XML Schema and user guide for reporting cross-border arrangements: Office of the Commissioner of Revenue→

November 16, 2020

Europe

Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties

November 12, 2020

Switzerland’s Federal Council, at its November 11 meeting, approved . . .

Europe

Russia, Malta signed protocol to tax agreement raising withholding tax on dividends and interest to 15 percent: TASS→

October 2, 2020

OECD publishes tax information exchange reviews for Anguilla, Chile, China, Gibraltar, Greece, Korea, Malta, Papua New Guinea, Uruguay: OECD→

September 3, 2020

Europe

Malta publishes regulations implementing EU anti-tax avoidance directives: Malta Office of Commissioner for Revenue→

August 31, 2020

Europe

Russia, Malta agree to amend treaty to raise withholding tax rate for interest, dividend payments to 15 percent: Reuters→

August 19, 2020

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

Europe

Malta updates consolidated group rules: Office of the Commissioner for Revenue→

June 10, 2020

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 . . .

Europe

Malta amends notional interest deduction guidelines

November 7, 2019

Malta, on November 7, announced amendments to its notional interest . . . .

Europe

Malta publishes patent box rules for IP consistent with qualified nexus approach: Malta Institute of Taxation→

August 20, 2019

Europe

Malta publishes new rules for consolidated groups: Government Gazette of Malta→

June 10, 2019

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

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

Armenia

Armenia, Malta to sign tax treaty: Armenpress→

June 27, 2019

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 . . .

Asia-Pacific

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

April 1, 2019

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered . . .

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 . . . .

Swedish ruling concludes parent-subsidary directive anti-avoidance rule inapplicable to dividend distribution to Maltese parent: EY→

May 17, 2017

Americas

US agrees to exchange country-by-country tax reports with Spain, announces effective dates of Malta and Guernsey agreements

December 21, 2017

The US has signed a competent authority agreement with Spain to exchange country-by-country tax reports on multinational firms, the IRS announced December 20. The IRS also announced the effective dates of competent authority agreements signed with Malta and Guernsey. All three . . .

EU Presidency to argue MNE anti-tax avoidance measures increase uncertainty, reduce investment: Francesco Guarascio & Jan Strupczewski / Daily Mail Online→

April 7, 2017

Americas

OECD reports assess tax dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

August 30, 2018

Peer review reports assessing the cross-border tax dispute resolution process in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal prepared by the “Inclusive Framework on BEPS,” . . .

Americas

OECD requests feedback on tax treaty dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

November 24, 2017

The OECD on November 24 asked for taxpayer input to conduct stage 1 peer reviews of the tax dispute resolution processes in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal. Taxpayers are . . .

Americas

Australia may exercise transfer pricing reconstruction power, will change approach to allocation of risk, official says

August 22, 2018

The Australian Taxation Office has not yet used its sweeping power to reconstruct transactions for transfer pricing purposes; however, that may soon change, Australian Deputy Commissioner Mark Konza said at the Tax Institute’s 2018 National Transfer . . .

Asia-Pacific

Singapore describes how the MLI affects 14 of its bilateral tax treaties

April 5, 2019

The Inland Revenue Authority of Singapore (IRAs) has provided information about how . . .

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin