Europe

Belgium

Belgium gazettes law clarifying earnings stripping rules: KPMG→

January 6, 2020

Europe

Germany’s new R&D tax incentive enters into effect: Karen Hensley-Chelstowska / Duff & Phelps→

January 6, 2020

Europe

Isle of Man updates guidance on tax residence

January 6, 2020

The Isle of Man’s Treaty Income Tax Division on January 2 published a practice note addressing . . .

Europe

Ireland updates guidance for obtaining MAP assistance: Irish Tax and Customs→

January 6, 2020

Americas

Any US trade action over French DST would lead to retaliation and WTO challenge, minister warns: Reuters→

January 6, 2020

Asia-Pacific

Philippines close to tax treaty with Cambodia, negotiating treaty with Ireland

January 6, 2020

The Philippines Department of Finance today announced that . . .

Americas

Google to end use of ‘Double Irish, Dutch sandwich’ tax loophole: Edward Helmore / The Guardian→

January 4, 2020

Americas

Spain poised to enact digital services tax despite US threats of retaliation

January 2, 2020

Alma Delia Virto Aguilar, Ph.D., a visiting researcher at the University of Salamanca, discusses Spain’s plans to enact a digital services tax on the revenue of large multinationals . . .

Asia-Pacific

Hong Kong announces entry into force of Cambodia, Estonia tax treaties

December 30, 2019

The Hong Kong government on December 27 announced that new tax treaties with Cambodia . . .

Digital Economy

Estonia won’t enact a digital tax, minister says: ERR→

December 30, 2019

Europe

2020 Dutch Tax Plan passes: relevance for multinational enterprises

December 30, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, provide an update on the Dutch 2020 tax plan which significantly changes the taxation of multinationals . . .

Digital Economy

EU Parliament adopts resolution supporting an EU-wide digital tax should global negotiations fail: European Parliament→

December 22, 2019

Europe

Multilateral tax treaty to enter into force for Liechtenstein

December 22, 2019

Liechtenstein on December 19 deposited its instrument of acceptance of . . .

Africa

Shell publishes country-by-country tax report

December 22, 2019

Oil giant Royal Dutch Shell on December 17 published its country-by-country report data for 2018 on the internet, providing . . .

Africa

US Treasury official defends “pillar one” safe harbor proposal for new global tax rules

December 20, 2019

A senior US Treasury official on December 19 said that the US is recommending that the OECD’s proposal for a “unified approach to pillar one” be rewritten as an optional safe harbor rule because even a watered-down version . . .

Europe

Germany advances new EU financial transaction tax proposal

December 16, 2019

German tax practitioner, Ninja-Antonia Reggelin, discusses the latest proposal for an EU-wide financial transactions tax, presented by German Finance Minister Olaf Scholz on December 9 . . .

Cyprus

Ukraine-Cyprus tax treaty protocol would alter taxation of indirect real estate transfers

December 13, 2019

Leonid Karpov a partner at AC Crowe, Ukraine, discusses the new Ukraine-Cyprus tax treaty protocol, ratified on October 30 by Ukraine’s Parliament. . .

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Americas

France will challenge at WTO any US tariffs imposed in retaliation for DST, Finance Minister says: Geert De Clercq / Reuters→

December 11, 2019

Europe

Fiat to appeal State aid verdict with EU Court of Justice: Foo Yun Chee & Giulio Piovaccari / The New York Times→

December 11, 2019

Europe

Why the EU Commission won’t appeal the Starbucks judgment

December 10, 2019

Dimitrios Kyriazis, Head of the Law Faculty at the New College of the Humanities, London, discusses the Commission’s decision to not appeal the Starbucks State and the implications of the Court’s judgment for transfer pricing in Europe . . .

Americas

US publishes US-France joint statement on implementation of spontaneous exchange of country-by-country reports on multinationals: US Treasury→

December 9, 2019

Europe

Ireland updates guidance on FATCA implementation: Irish Tax and Customs→

December 9, 2019

Americas

France rejects US plan to turn pillar one of tax rewrite into a “safe harbor,” says EU should negotiate digital tax if global agreement falls through: Tom Ozimek / Epoch Times→

December 9, 2019

Europe

Montenegro joins the Inclusive Framework on BEPS to fight MNE tax avoidance

December 5, 2019

Montenegro has become the 136th country to join the Inclusive Framework on BEPS, a coalition of countries that have pledged to adopt . . .

Europe

Netherlands publishes first summaries of private tax rulings issued to MNE groups

December 5, 2019

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands” publication, on October 16, of the first redacted summaries of private tax rulings . . .

Africa

Is the US about to blow up the OECD’s compromise “pillar one” plan for taxing multinational group profit?

December 5, 2019

In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECD’s compromise proposal to overhaul the rules for allocating multinational group profit and related taxing. . .

Africa

OECD releases 186 comment letters on proposal for global minimum tax on multinational group profit

December 3, 2019

The OECD today released 186 comment letters in response to its request for assistance in the design of a global minimum tax on multinational group profit. The OECD also released the, , ,

Asia-Pacific

Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes

December 3, 2019

The Australian government on November 29 released the synthesized texts of tax . . .

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

EU Commission won’t challenge Starbuck’s State aid victory, Vestager says: Lewis Crofts and Nicholas Hirst / MLex Market Insight→

December 3, 2019

Americas

US trade officials propose tariffs of up to 100 percent on French goods to counter digital services tax

December 2, 2019

The office of the United States Trade Representative (USTR) today proposed retaliatory tariffs of up to 100 percent on French wine, cheese, handbags, makeup, china, and similar items, after concluding that France’s digital services tax . . .

Africa

Tax researcher disagrees with OECD’s Ben Dickenson, says developing countries should negotiate global tax rewrite as a block to even out power imbalance: Joy Ndubai / ICTD→

November 29, 2019

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Africa

OECD celebrates Global Forum’s 10th anniversary

November 29, 2019

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland discusses the 10th anniversary celebration of the OECD-led Global Forum on Transparency and Exchange of Information where more than 386 delegates from more than 142 jurisdictions met in Paris . . .

Europe

UK Labour Party pledges to tax MNEs as unitary firms

November 27, 2019

The UK Labour Party in its manifesto for the upcoming election has committed to . . .

Bulgaria

Bulgaria’s balanced Budget 2020 adopted on first reading by parliament

November 26, 2019

Ivan Dimitrov, in-house legal counsel in Sofiа, Bulgaria, discusses Bulgaria’s balanced budget draft law for 2020, adopted by Parliament on November 12 . . .

Asia-Pacific

Japan, Serbia commence tax treaty negotiations

November 22, 2019

Japan’s Ministry of Foreign Affairs today announced that . . .

Americas

OECD’s digital tax plan would raise little revenue for France, Germany, US, and China, French Council of Economic Analysis concludes: Financial Times→

November 19, 2019

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