Europe

Americas

US Republican and Democrat Senate leaders reiterate support for retaliatory tariffs on France if DST not repealed: The United States Senate Committee on Finance→

July 14, 2020

Americas

US imposes 25 percent tariff on USD 1.3b French luxury goods in retaliation for French DST but suspends tax for up to six months: Doug Palmer / Politico→

July 11, 2020

Europe

Dutch MEP Paul Tang expected to chair EU Parliament tax subcommittee: EURACTIV.com→

July 10, 2020

Americas

EU General Court should conclude that Apple branch’s stateless income should not be taxed in Ireland because assets, functions, risks not located there, Irish economist says: Seamus Coffey→

July 9, 2020

Europe

EU General Court decisions on Ireland v Commission, Apple v Commission expected next week

July 9, 2020

The EU General Court will release its decisions in the Apple state aid cases — Ireland v Commission and Apple Sales International . . .

Africa

New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior

July 8, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark discusses the OECD’s July 9 release of data on 4,000+ MNE groups . . .

Africa

UN committee to draft model tax treaty provisions addressing digital economy, transfer pricing manual updates approved

July 8, 2020

The UN Committee of Experts on International Cooperation in Tax Matters, at its 20th session, agreed to consider adding new provisions addressing the taxation of the digital economy to the UN Model Double Taxation Convention between Developed and Developing Countries, UN officials . . .

Africa

OECD publishes model rules for tax reporting by gig economy platform operators

July 8, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the OECD’s July 3 release of model rules for tax reporting by platform operators. . .

Europe

The Netherlands’ new DAC6 requirements: what multinationals need to know

July 8, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland NV discuss the Netherlands’ DAC6 guidance, released on June 26, and the implications for multinational group taxpayers . . .

Europe

EU to launch tax observatory

July 8, 2020

Francesca Amaddeo a researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the European Commission’s July 6 call for proposals for the creation of an EU tax observatory . . .

Europe

Germany won’t opt for six-month DAC6 reporting delay: Isabel Gottlieb / Bloomberg Tax→

July 7, 2020

Europe

UK says Big Four must separate auditing and consulting practices by 2024 but can share the same parent company: Financial Reporting Council→

July 7, 2020

Europe

Netherlands announces new policies for resolving cross-border tax disputes

July 7, 2020

Jian-Cheng Ku and Rhys Bane, DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands government’s June 22 announcement of new policies regarding the mutual agreement procedures (MAPs) and arbitration procedures in its tax treaties . . .

Europe

Ireland extends DAC6 reporting requirement by six months: Irish Tax and Customs→

July 6, 2020

Denmark

Denmark Supreme Court rules in favor of Adecco in landmark transfer pricing decision

July 1, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark, discusses the Denmark Supreme Court’s June 25 decision in the Adecco case, a dispute involving the tax deductibility of royalties and the sufficiency of transfer pricing documentation . . .

Europe

Germany announces tax policy goals for Council of the EU Presidency

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses Germany’s July 1 announcement of its tax policy priorities for its six-month Council of the EU Presidency . . .

Africa

Draft toolkit on the art of tax treaty negotiation offers tips for developing countries

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .

Europe

German parliament approves VAT rate cut to 16 percent: Reuters→

June 30, 2020

Belgium

Belgium parliament digital tax hearing considers effect of reforms on patent box, features negotiation update by Pascal Saint Amans: Johan Bernardo Langerock / Twitter→

June 30, 2020

Africa

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

June 29, 2020

Economist Dr. J. Harold McClure, New York, NY, discusses likely transfer pricing issues associated with Gilead Sciences’ COVID-19 therapy, remdesivir, comparing the transfer pricing treatment of Gilead Sciences’ blockbuster HIV and hepatitis C virus drugs . . .

Europe

Ireland extends DAC6 reporting deadlines to September 30 consistent with EU agreements: Irish Revenue→

June 29, 2020

Europe

Poland poised to launch new corporate income tax regime

June 29, 2020

Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish government’s announcement that it will introduce the so-called Estonian solution into Poland’s corporate income tax system . . .

Europe

Netherlands confirms extension of DAC6 rules: Mehdi el Manouzi / Twitter→

June 26, 2020

Europe

Netherlands to deny COVID-19 aid to companies located in low-tax countries or that make royalty or interest payments to low tax countries: Government of Netherlands→

June 24, 2020

Africa

Finland funds ATAF effort to strengthen African tax systems: African Tax Administration Forum→

June 24, 2020

Council of the European Union

EU Council agrees to extend DAC6 reporting, financial account reporting deadlines

June 24, 2020

The EU Council today adopted an amending directive allowing EU member states the option to delay by six months the time for filing and exchanging information to meet . . .

Europe

EU Member States agree to defer start date of e-commerce VAT rules

June 24, 2020

EU Member State representatives on Coreper (the Permanent Representatives Committee) today reached . . .

Europe

EU Parliament creates permanent tax subcommittee

June 22, 2020

Francesca Amaddeo, Researcher, Tax Law at the Competence Centre (SUPSI), Manno, Switzerland, disccusess the European Parliament’s creation of a permanent subcommittee on tax matters . . .

Africa

The OECD’s “no Plan B” approach on digital taxation backfires

June 22, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, discusses the breakdown of global digital tax talks and the likely future of negotiations . . .

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

US has abandoned negotiations with EU on digital tax, proposes pausing OECD-led negotiations, US officials say: Andrea Shalal / Reuters→

June 17, 2020

Africa

Transfer prices based on EBITDA, not EBIT

June 17, 2020

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

Europe

Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute

June 17, 2020

Michael Vorndran, Nord Advisory AS, Oslo, Norway, discusses a May 28 decision of the Norwegian Supreme Court in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office . . .

Europe

Italy clarifies VAT reporting obligations of online marketplaces

June 16, 2020

Davide Anghileri, a tax researcher with the University of Lausanne, Switzerland, discusses June 1 Italian Revenue Agency guidance clarifying the VAT reporting obligations of online platforms . . .

Americas

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

June 15, 2020

Dr. Harold McClure, a New York economist, analyzes a recent Swedish transfer pricing case, Puma Nordic, and a 2015 Indiana transfer pricing case, Columbia Sportswear, where the transactional net margin method (TNMM) was applied to determine the return of a distribution affiliate . . .

Europe

German cabinet passes stimulus tax measures

June 12, 2020

Berlin tax practitioner, Ninja-Antonia Reggelin, notes today’s passage by Germany’s cabinet of law implementing the tax measures relevant to business, identifying a few changes from the German finance ministry’s earlier draft . . .

Council of the European Union

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

Europe

US Republican and Democrat Senate leaders reiterate support for retaliatory tariffs on France if DST not repealed: The United States Senate Committee on Finance→

US imposes 25 percent tariff on USD 1.3b French luxury goods in retaliation for French DST but suspends tax for up to six months: Doug Palmer / Politico→

Dutch MEP Paul Tang expected to chair EU Parliament tax subcommittee: EURACTIV.com→

EU General Court should conclude that Apple branch’s stateless income should not be taxed in Ireland because assets, functions, risks not located there, Irish economist says: Seamus Coffey→

EU General Court decisions on Ireland v Commission, Apple v Commission expected next week

New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior

UN committee to draft model tax treaty provisions addressing digital economy, transfer pricing manual updates approved

OECD publishes model rules for tax reporting by gig economy platform operators

The Netherlands’ new DAC6 requirements: what multinationals need to know

EU to launch tax observatory

Germany won’t opt for six-month DAC6 reporting delay: Isabel Gottlieb / Bloomberg Tax→

UK says Big Four must separate auditing and consulting practices by 2024 but can share the same parent company: Financial Reporting Council→

Netherlands announces new policies for resolving cross-border tax disputes

Ireland extends DAC6 reporting requirement by six months: Irish Tax and Customs→

Denmark Supreme Court rules in favor of Adecco in landmark transfer pricing decision

Germany announces tax policy goals for Council of the EU Presidency

Draft toolkit on the art of tax treaty negotiation offers tips for developing countries

German parliament approves VAT rate cut to 16 percent: Reuters→

Belgium parliament digital tax hearing considers effect of reforms on patent box, features negotiation update by Pascal Saint Amans: Johan Bernardo Langerock / Twitter→

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

Ireland extends DAC6 reporting deadlines to September 30 consistent with EU agreements: Irish Revenue→

Poland poised to launch new corporate income tax regime

Netherlands confirms extension of DAC6 rules: Mehdi el Manouzi / Twitter→

Netherlands to deny COVID-19 aid to companies located in low-tax countries or that make royalty or interest payments to low tax countries: Government of Netherlands→

Finland funds ATAF effort to strengthen African tax systems: African Tax Administration Forum→

EU Council agrees to extend DAC6 reporting, financial account reporting deadlines

EU Member States agree to defer start date of e-commerce VAT rules

EU Parliament creates permanent tax subcommittee

The OECD’s “no Plan B” approach on digital taxation backfires

OECD to stick to digital tax negotiation timetable despite US opposition

US has abandoned negotiations with EU on digital tax, proposes pausing OECD-led negotiations, US officials say: Andrea Shalal / Reuters→

Transfer prices based on EBITDA, not EBIT

Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute

Italy clarifies VAT reporting obligations of online marketplaces

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

German cabinet passes stimulus tax measures

EU compromise gives states the option to delay DAC6 reporting by six months: KPMG→

Malta updates consolidated group rules: Office of the Commissioner for Revenue→

Ireland updates guidance on allowances for scientific research: Tax and Duty Manual→