Europe

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Europe

Poland issues guidance on controversial rules requiring additional disclosures for transactions involving tax havens

Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics, discusses new Polish guidance on disclosures required by taxpayers that conduct business with tax haven entities. . .

Europe

Ireland updates and expands tax guidance on anti-hybrid rules

Irish Revenue updated the anti-hybrid provisions in its tax manual on March 29 to reflect amendments made by Finance Act 2020 with respect to how the anti-hybrid rules apply to a worldwide system of taxation. . .

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance

Greece and Hungary have deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), the OECD announced March 30. . .

Digital Economy

New Italian guidance addresses digital service tax details

March 30, 2021

Giuliana Polacco & Annarita De Carne, Studio Legale Bird & Bird, Milan, discuss the Italian Revenue Agency’s long-awaited guidance issued on March 23 clarifying the application and implementation of the digital service tax. . .

Digital Economy

EU Parliament committee adopts resolution on digital taxation

March 30, 2021

The European Parliament’s Committee on Economic and Monetary Affairs (ECON) on March 23 adopted a motion for a European Parliament resolution on digital taxation, OECD negotiations, tax residency of digital companies, and a possible European digital tax. . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Europe

German cabinet adopts bill closing MNE tax avoidance loopholes

March 26, 2021

Germany’s federal cabinet on March 24 adopted a bill implementing the EU’s Anti-Tax Avoidance Directive, including stricter rules to fight aggressive tax avoidance strategies used by multinational corporations. . .

Africa

OECD details 30 countries’ approach to cross-border tax dispute arbitration

March 25, 2021

The OECD today added information to its website on 30 countries’ processes for arbitrating cross-border tax . . .

Europe

UK consults on aligning transfer pricing documentation requirements with OECD approach

The UK HM Revenue and Customs is considering potential new transfer pricing documentation requirements that would require businesses to prepare and provide specific documentation to support their transfer pricing . . .

Europe

Ireland MEP says Parliament proposal to dispense with majority voting on tax issues that “distort” the single market skirt the treaty: Sarah Collins / Independent.ie→

Europe

Netherlands legislative proposal tackles transfer pricing mismatches

Jian-Cheng Ku and Tim Mulder, of DLA Piper Netherlands N.V., discuss the Dutch government’s publication on March 4 of its legislative proposal to tackle double non-taxation resulting from transfer pricing mismatches. . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Greek transfer pricing guidance addresses the COVID-19 pandemic

Emmanouela Kolovetsiou-Baliafa of KG Law Firm, Athens, Greece, discusses a Greek Independent Authority for Public Revenues circular providing guidance on the transfer pricing implications of the COVID-19 pandemic. . .

Europe

EU approves DAC 7 rules on digital platform tax reporting, joint audits

As expected, the EU Council on March 22 approved DAC 7, establishing new EU-wide rules that require digital platforms . . .

Europe

EU sues UK for failure to recover Gibraltar tax benefits from multinationals

March 23, 2021

The European Commission reported on March 19 that it is referring the UK to the Court of Justice of the European Union for failing to comply with the Commission’s decision requiring it to recover €100 million of illegal state aid in Gibraltar. . .

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Europe

Public country-by-country reporting is inevitable, EU Commission official says: Naomi O’Leary / The Irish Times→

March 18, 2021

Asia-Pacific

Australia and Belgium enter into a memorandum of understanding on procedure for arbitration of tax disputes: Australian Taxation Office→

March 18, 2021

Europe

Ireland consults on adoption of authorized OECD approach for attributing profits to branches

Ireland’s Department of Finance on March 16 launched a public consultation on its proposal to adopt into Irish law the “authorized OECD approach” for the attribution . . .

Digital Economy

CJEU confirms Polish and Hungarian progressive turnover taxes do not violate EU law

On March 16, the Court of Justice of the European Union upheld the General Court’s judgments that two progressive turnover taxes – a Polish tax on the retail sector and a Hungarian tax on advertisement revenue – do not violate EU state aid law. . .

Americas

Mathias Cormann appointed OECD Secretary General

The OECD council on March 15 named former Australian finance minister Mathias Cormann as its next leader beginning in June. He will become the first secretary-general from. . .

Europe

Ireland updates guidance on self-certification system allowing payment of interest and royalties with deductions at the applicable tax treaty rate: Irish Tax and Revenue→

Africa

EU to implement digital levy regardless of OECD-led effort

The EU Commission will continue to press ahead with its proposal for an EU digital levy to fund EU operations even if a global international tax . . .

Europe

Ireland pays €1 million to the Netherlands for MAP settlement regarding the location of KPN insurance unit’s profits in 2014 and 2015: Mark Paul / The Irish Times→

Europe

UK proposes ‘super deduction’ for plant and machinery, launches R&D tax incentive review

The UK published its Finance Bill on March 11, detailing the tax provisions announced in the 2021 UK budget, including the super deduction to boost economic recovery and a review of the UK’s current R&D tax incentives. . .

Council of the European Union

EU advances DAC 7 proposals to share digital platform tax information