Africa
Europe
Cyprus
Europe
Digital Economy
Europe
Americas
Digital Economy
Europe
Europe
Europe
Europe
Sweden proposes to deny tax deductions for interest payments to companies located in EU blacklist countries
Madeleine Thörning, a transfer pricing specialist at Thorning Koponen Consulting in Stockholm, discusses the Swedish government’s September 3 proposal to deny tax deductions for interest payments made to companies located in countries listed on the European Union’s list of non-cooperative jurisdictions . . .
Digital Economy
Bulgaria
Europe
Digital Economy
Europe
Europe
Europe
Europe
Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company
Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a recent Italian Supreme Court decision addressing whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes where the court applied the European Court of Justice’s holdings in the so-called Danish cases . . .
Americas
Africa
UN model treaty proposal would impose withholding tax on software payments
Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .
Europe
Poland clarifies treatment of dividends under transfer pricing rules
Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses guidance issued August 6 by Poland’s Minister of Finance that addresses whether a dividend payment among associated companies falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. . . .
Cyprus
Europe
Europe
Europe
Americas
Americas
Africa
Europe
Americas
Americas
Europe
Africa
Asia-Pacific
Americas
Europe
Africa
Asia-Pacific
