Americas

The Pillar Two model rules: a train wreck in the making

Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.

Europe

Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract

Pilar Barriguete and Victoria Arozamena, Kroll Advisory, S.L., discuss Spain’s recent tendency to challenge intragroup services, denying its corporate income tax deductibility; this view is most recently reflected in the Spanish National Court’s January 25 ruling that it did not consider the provision of intragroup services to be sufficiently proven in the absence of a written contract.

Denmark

Danish High Court rules on the application of EU Arbitration Convention and MAP in transfer pricing case

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a recent transfer pricing ruling from the High Court of Eastern Denmark in a case on the application of the EU Arbitration Convention and mutual agreement procedures; this ruling is an indication that settling disputes by arbitration is an outcome that will become ever more important in the future of Danish tax law.

Americas

A regulatory tax hike on US multinationals

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Europe

Romania approves changes to advance tax ruling program

Adrian ȚAGA, Romania’s National Tax Agency, discusses the Romanian government’s February 16 approval of changes to the organizational structure of both the Ministry of Finance and the National Tax Agency, allowing the transfer of the advance tax rulings (ATR) unit to the Ministry of Finance.