Europe

Africa

UN tax committee to consider adding new automated digital services article to model convention

October 20, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss the UN Committee of Experts on International Cooperation in Tax Matters plans to consider at its 21st session a proposed new model tax convention article that addresses automated digital services income . . .

Africa

UN tax committee to weigh updates to model treaty, transfer pricing manual

October 20, 2020

The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its 21st session today, meeting virtually to discuss transfer pricing . . .

Asia-Pacific

Synthesized text of Australia–Russia tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Asia-Pacific

Synthesized text of Australia–Czech Republic tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Europe

EU Advocate General concludes that Poland’s retail tax and Hungary’s advertising tax, both based on turnover, are not State aid even though they primarily affect larger undertakings: Court of Justice of the European Union→

October 15, 2020

Americas

France reinstates digital tax, courting trade war: Bjarke Smith-Meyer & Elisa Braun / POLITICO→

October 14, 2020

Africa

OECD Pillar One: a closer look at the proposal’s impact and the questions that remain

October 14, 2020

Philippe Paumier of VECTOR TP, Paris, takes a closer look at the supporting impact analysis of the OECD blueprint on pillar one and considers the future of the proposal . . .

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

Europe

The economics of leasing and the arm’s length standard

October 9, 2020

Dr. Harold McClure, an New York City economist, presents a model of what would compensate arm’s length lease payments and applies this model to ship leasing . . .

Denmark

Denmark tax tribunal considers sufficiency of transfer pricing documentation

October 9, 2020

Susi Baerentzen, Ph.D., Copenhagen, discusses a decision of the Danish National Tax Tribunal, published on September 24 which assesses the Danish tax administration’s discretionary transfer pricing assessment power. . . .

Americas

Cayman Islands Premier welcomes island’s removal from EU tax blacklist: Ministry of Financial Services, Cayman Islands →

October 8, 2020

Digital Economy

Spain’s upper house passes financial transactions tax, digital services; both taxes to go into effect in January: Cristina Enache / Tax Foundation→

October 8, 2020

Americas

Barbados appalled at EU’s “unjust” and “disproportionate” decision to list the Island as a non-cooperative jurisdiction for tax purposes, Prime Minister says: NationNews→

October 8, 2020

Denmark

Draft Danish bill would tighten transfer pricing rules

October 7, 2020

Susi Baerentzen, Ph.D., Copenhagen, discusses proposed changes to Denmark’s transfer pricing law, released for public consultation on October 4 . . .

Asia-Pacific

The EU’s latest list of non-cooperative tax jurisdictions

October 7, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses October 6 revisions to the EU Commission’s list of non-cooperative jurisdictions in taxation . . .

Belgium

The new Belgian government’s agreement: a symphony with tax notes

October 7, 2020

Geoffroy Galéa, Of Counsel and Head of the Tax Practice at Fieldfisher, Brussels, discusses a policy paper, agreed to September 30 by Belgium’s new government, the so-called “Vivaldi coalition,” which includes the coalition’s position on international tax matters . . .

Africa

COVID-19 test producer Qiagen’s intercompany financing – the transfer pricing issues

October 6, 2020

Dr. Harold McClure, a New York City Economist, discusses an analysis by Vincent Kiezebrink and Jasper van Teeffelen which accuses biotech firm Qiagen of base erosion through the use of intercompany loans . . .

Africa

Australia to change to corporate tax residency test

October 6, 2020

The Australian government will propose to change the corporate residency test used to determine if a company incorporated offshore is liable for income tax in Australia, budget documents released today . . .

Europe

NGO report reveals German pharma company Qiagen’s tax avoidance through intercompany loans: SOMO→

October 2, 2020

Europe

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

October 2, 2020

Europe

EU Commission publishes VAT e-commerce explanatory guidance:→

October 2, 2020

Europe

Dutch opposition party proposes controversial dividend exit tax

September 30, 2020

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper, Amsterdam, discuss a Dutch proposal to introduce an exit tax to the dividend withholding tax which, if enacted, would apply to Dutch resident companies undertaking cross-border reorganizations as of September 18 . . .

Europe

UK affiliate of Airbnb UK hit with £1.8 million (USD 2.3 million) tax bill for 2019 after audit: Reuters→

September 30, 2020

Digital Economy

EU publishes explanatory notes on VAT e-commerce rules: European Commission→

September 30, 2020

Denmark

Spain must recover illegal state aid for tax lease schemes

September 30, 2020

Susi Baerentzen, Ph.D., Copenhagen, Denmark, discusses the General Court of the European Union’s September 23 ruling in the Spanish tax leasing case, aka the Lico Leasing case, a long-running taxation state aid dispute that had been referred back from the European Court of Justice in 2018 . . .

Europe

EU to propose system for harmonized withholding tax relief

September 30, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a tax proposal included in the EU Commission’s September 24 Capital Markets Union Action Plan . . . .

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

Europe

The 2021 Dutch tax plan: key takeaways for multinational enterprises

September 28, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper, Amsterdam, discuss the Dutch government’s September 15 tax legislative proposals, focusing on the items most relevant to multinational enterprises . . .

Europe

EU Commission appeals Apple State aid ruling

September 25, 2020

The European Commission today announced that it has appealed the EU General Court’s ruling in the Apple State aid case to . . .

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

September 25, 2020

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Europe

Poland provides more details on plan to require large firms to publicize tax strategy

September 24, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses a September 16 bill published by the Polish government requiring large corporations to prepare and publish a report on the execution of their tax strategy each fiscal year . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

September 23, 2020

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

September 23, 2020

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Europe

UK Autumn 2020 Budget canceled: London Evening Standard→

September 23, 2020

Europe

Ireland proposes revisions to investment limited partnership structure: Ireland Department of Finance→

September 23, 2020

Americas

EU leaning towards appealing Apple tax decision, unnamed senior tax officials say, deadline to appeal is Sept. 25: Simon Van Dorpe / Politico→

September 23, 2020

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available

September 23, 2020

The international tax community needs to again thank McGill Professor Allison Christians for getting ahold of leaked copies of the latest versions of the pillar one and pillar two digital tax . . .

Africa

EU may address public country-by-country reporting this year, German minister says

September 21, 2020

The EU may soon take up the issue of whether country-by-country reports detailing the tax affairs of large multinationals should be made public, German Federal Minister of Finance Olaf Scholz said today . . .

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