Europe
Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia
Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .
The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office
Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .
EU Commission tax package includes review of tax law approval process, VAT reform
Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland discusses the EU Commission’s tax package, released July 15; the Commission says it will explore a new mechanism for enacting tax legislation without the approval of all EU states and offers significant amendments to European VAT rules . . .
Intercompany interest deductions in the extractive sector
Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .