Europe

Americas

US and Monaco agree to exchange country-by-country tax reports on large multinationals

November 30, 2020

The US IRS today announced that the US and Monaco have agreed . . .

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

Americas

France cancels suspension of digital service tax collection, sends Facebook, Amazon, other large tech firms tax bills due in December: Reuters→

November 25, 2020

Africa

NGO report estimates annual corporate tax avoided per country, says USD 245 billion lost annually from MNEs shifting profits to tax havens: Tax Justice Network→

November 25, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Europe

Guernsey publishes updated MAP guidance: States of Guernsey Revenue Service→

November 23, 2020

Europe

Irish guidance addresses new VAT rules for cross-border business-to-consumer e-commerce activities: Tax and Duty Manual→

November 20, 2020

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Americas

Blackrock prevails in UK transfer pricing dispute

November 18, 2020

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Europe

EU plans to revise energy taxation by next summer to promote reduced emissions, head of climate policy says: Kate Abnett / Reuters→

November 17, 2020

Europe

UK report evaluating research and development credit concludes that while the tax credit cost £2.4bn in 2017-18, it may have stimulated £5.8–£6.5bn of additional corporate spending: Georgia Scott & Tim Glinert / HM Revenue & Customs→

November 17, 2020

Europe

UK report evaluating patent box finds a 10 percent increase in investment by companies that using the tax incentive versus those that do not: Max Rowe-Brown & Huw James /HM Revenue & Customs→

November 17, 2020

Europe

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

November 16, 2020

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 2020

Europe

UK draft tax proposals include hybrid mismatch fixes, R&D tax credit cap

November 12, 2020

The UK government today proposed additional tax legislation for Finance Bill 2021 . . .

Europe

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

November 12, 2020

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

Digital Economy

Nations must agree to tax regime for digital firms that produces “a fair tax system that provides long-term sustainable revenues” or the EU will make its own proposal, von der Leyen says: European Commission→

November 12, 2020

Europe

Guernsey extends country-by-country reporting filing deadlines for constituent entities because of COVID-19: States of Guernsey→

November 12, 2020

Europe

Ireland updates guidance on R&D tax credit refunds: Irish Tax and Customs→

November 11, 2020

Europe

Swiss government approves new law governing tax treaties

November 11, 2020

Davide Anghileri, University of Lausanne, discusses the Switzerland Federal Council’s November 4 decision to support new legislation applicable to tax treaties . . .

Europe

Luxembourg and Russia sign treaty raising tax on dividends, interest: Yannick Lambert / Luxembourg Times→

November 10, 2020

Europe

Poland tax guidance confirms controversial position on year-end transfer pricing adjustments

November 5, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses a Poland Ministry of Finance public consultation on an explanatory note addressing taxpayers’ ability to make year-end, self-initiated, transfer pricing adjustments . . .

Europe

EU court rules Romania can impute interest on intercompany loans, but what should the rate be?

November 4, 2020

Dr. Harold McClure, a New York City economist, notes the EU Court of Justice’s October 8 ruling confirming that Romania’s tax authority can require arm’s length interest rates on intercompany loans and discusses how one would determine the interest rate . . .

Europe

Irish High Court rejects Perrigo’s challenge to procedural issues unrelated to merits of USD 1.9 billion tax case involving tax rate applicable to IP sales: Conor Humphries / Reuters→

November 4, 2020

Europe

Ireland provides guidance on DAC6 reporting of cross-border arrangements: Irish Tax and Customs→

November 3, 2020

Europe

Commission opinion asserts that Spain has missed deadline to transpose hybrid mismatch directive into law and threatens lawsuit unless action is taken within two months: European Commission→

November 2, 2020

Europe

Commission asks France to change taxation of foreign investment fund capital gains arising from sales of French company shares: EU Commission→

November 2, 2020

Europe

EU Commission refers Greece to Court of Justice over rules that provide different tax treatment for losses incurred domestically and those incurred in other EU/EEA state: EU Commission→

November 2, 2020

Europe

CJEU rules that EU freedom of establishment does not preclude application of Romanian transfer pricing law imputing market-rate interest on loan between parent and branch located in another state: Court of Justice of the European Union→

October 30, 2020

Europe

Of 39 large EU banks, 31 operate in tax havens and 29 report large profits in countries where no employees are located, suggesting profit shifting, new report concludes: Elena Gaita & Linda Kunertova / Transparency International EU→

October 29, 2020

Europe

Spanish draft budget proposes to limit large MNEs’ tax exemption for dividends and capital gains from subsidiaries, tax real estate investment trusts: Carlos E. Cue & Laura Delle Femmine / El Pais→

October 28, 2020

Europe

Ireland releases tax bill, announces plan to enact interest deduction limits from 2022

October 28, 2020

Warren Novis, BDO Ireland, Dublin, discusses Ireland’s Finance Bill 2020, released October 22, which includes several tax provisions affecting multinational enterprises and Ireland’s plans to enact EU-compliant interest deduction limitations . . .

Americas

Croatia to initiate tax treaty negotiations with the United States

October 28, 2020

Ksenija Cipek, Head of Tax Risk Analysis, Ministry of Finance, Tax Administration, Croatia, discusses the Republic of Croatia’s decision to initiate proceedings to conclude a tax convention with the United States. . . .

Denmark

Denmark courts reject tax authority’s formalistic transfer pricing approach

October 28, 2020

Susi Baerentzen, Ph.D., Copenhagen, analyzes a string of transfer pricing cases decided over the past two years by Denmark’s Supreme Court and high courts which have ruled against the tax administration’s formalistic approach, the most recent example being the July 2 Western High Court ruling in the ECCO shoe case . . .

Europe

Professors analyze EU General Court decision in Apple, noting drawbacks of using state aid concept to counter MNE tax avoidance: Stephen Daly, Ruth Mason / SSRN→

October 27, 2020

Europe

EU Commission work programme reveals plan for new taxes

October 26, 2020

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland discusses the EU’s latest tax policy priorities, as expressed in the EU Commission’s Work Programme 2021 . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Africa

The UN transfer pricing manual’s updated China chapter: wine and smartphones

October 20, 2020

Dr. J. Harold McClure, a New York City economist, discusses the newly revised China chapter of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released in advance of the 21st session of Committee of Experts on International Cooperation in Tax Matters . . .

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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