Europe

The OECD today released more than 250 comment letters in response to a request for public . . .

Europe

Ireland tax office outlines procedure and operation of co-operative compliance framework for large corporates: Tax and Duty Manual→

Europe

German transfer pricing guidance addresses taxpayers’ obligation to cooperate with tax office

Konstantin Sakuth of Linklaters LLP, Munich, discusses December 3 transfer pricing guidance issued by Germany’s Federal Ministry of Finance that addresses a multinational group taxpayer’s obligation to cooperate with the tax authorities concerning income allocation . . .

Africa

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

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

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

Americas

Taxing multinational group excess profit in the US, UK, and Belgium

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Asia-Pacific

Japan, Switzerland to negotiate tax treaty amendments

Japan’s Ministry of Finance today announced that the government of Japan and the Swiss . . .

Africa

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

Europe

UK seeks feedback on proposed VAT changes that reflect digital platform “sharing economy”

December 14, 2020

The UK’s HM Treasury has requested public feedback on whether the VAT rules should be changed . . .

Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

December 14, 2020

Europe

Blackrock’s transfer pricing battle with the UK: unexplored intercompany financing issues

December 11, 2020

Dr. J. Harold McClure, a New York City economist, discusses intercompany loan pricing issues revealed in a November 3 UK Tribunal decision favoring the UK affiliate of investment management group, Blackrock . . .

Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→

December 11, 2020

Europe

EU tax haven blacklist listing procedures should be updated to screen EU states, improve listing and delisting transparency, toughen criteria, tax subcommittee concludes: European Parliament→

December 10, 2020

Europe

Netherlands resisting Russian proposal to amend tax treaty to increase withholding for dividends and interest to 15 percent: TASS→

Africa

Transactional profit indicators for the TNMM are not viable

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

88% of countries engaging in automatic exchange of financial account information have satisfactory legal frameworks, Global Forum peer review concludes: OECD→

Europe

EU states agree to share digital platform information to aid tax collection

Francesca Amaddeo, a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, reports that the EU Council has reached technical agreement on DAC7, concerning the exchange of information provided by digital platforms, such as Amazon and Airbnb, for tax purposes . . .

Europe

Portugal must recover State aid granted to companies through tax reductions in Madeira Free Zone because jobs not created in Madeira, as required, Commission concludes: European Commission→

Europe

EU Commission asks Italy to end corporate tax exemptions for ports, concludes rules grant illegal State aid: EU Commission→

Europe

Italy updates transfer pricing regulations

Angela Valente, Diego Conte, and Alessandro Foti of De Berti Jacchia, Milano, discuss Italian transfer pricing documentation regulations issued on November 23 that, among other things, address low-value-added services, new signature requirements, and the definition of small and medium-sized entities . . .

Belgium

CJEU should reverse Belgian excess profits tax decision, Advocate General says

December 4, 2020

The Advocate General of the Court of Justice of the Europe Union (CJEU), in a December 3 opinion, advised the CJEU to overturn . . .

Americas

US and Germany again agree to exchange country-by-country reports on large multinationals

December 4, 2020

The competent authorities of the US and Germany have issued a joint statement, agreeing . . .

Americas

A new EU-US joint agenda for global change should include fair taxation of digital economy, EU officials say: EU Commission→

Europe

Gabriel Zucman to head new European Tax Observatory: Sven Giegold→

Americas

France to request EU retaliation if US enacts trade sanctions in response to French digital services tax, Le Marie says: Reuters→

Africa

OECD toolkit helps developing country tax administrations satisfy confidentiality and data security requirements for automatic exchange of information with other countries: OECD→