Europe

Czech Republic

Czech government approves 7% digital tax, measure to be considered by parliament: Reuters→

November 19, 2019

Europe

Danish staffing company can’t deduct royalties paid to Swiss parent, High Court rules

November 19, 2019

Peter S. Andersen, Transfer Pricing Partner at Questro International, Amsterdam, analyzes a key decision of Denmark’s Eastern High Court, issued October 28, where the court agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its Swiss parent for the use of marketing intangibles . . .

Europe

Ireland study shows €10 billion increase in corporate tax receipts in 2018 largely due to increased corporate profitability, with almost 80% of receipts from pharmaceutical, technology, and finance sectors: Ireland Department of Finance→

November 18, 2019

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Americas

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes

November 18, 2019

The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border tax dispute resolution process in Aruba, Bahrain, Barbados,. . .

Europe

Poland’s new cooperative compliance program for large taxpayers

November 15, 2019

Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses Poland’s new large taxpayer compliance program . . . .

Europe

German finance ministry approves reporting obligation for cross-border tax: Federal Ministry of Finance→

November 12, 2019

EU Council addresses VAT for e-commerce, excise tax, tax blacklist, digital tax

November 12, 2019

MNE Tax Contributing Editor, Davide Anghileri, of the University of Lausanne, discusses political agreements reached by the European Council during its meeting of November 8 that are related to taxation . . .

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Europe

Malta amends notional interest deduction guidelines

November 7, 2019

Malta, on November 7, announced amendments to its notional interest . . . .

Americas

EU Code of Conduct Group proposes changes to tax blacklist

November 7, 2019

Davide Anghileri, University of Lausanne, Switzerland discusses the EU Code of Conduct Group’s November 4 recommendations for changes to the EU tax blacklist . ..

Europe

Netherlands, UK liable for overseas territories’ unpaid customs duties, EU court concludes: The Daily Herald Newspaper St. Maarten→

November 6, 2019

Asia-Pacific

Switzerland’s Federal Council approves amendments to tax treaties with New Zealand, Netherlands, Norway, Sweden

November 6, 2019

Switzerland’s Federal Council on November 6 approved four tax treaty protocols . . .

Americas

Ukrainian Parliament ratifies FATCA agreement with US: 112 UA→

October 31, 2019

Europe

UK Labour Party may champion formulary apportionment, MP says: The Labour Party→

October 30, 2019

Europe

Multilateral tax treaty to enter into force for Latvia

October 30, 2019

The OECD announced on October 29 that Latvia has deposited its instrument . . .

Bosnia and Herzegovina

Bosnia and Herzegovina signs BEPS MLI on multinational group taxation

October 30, 2019

The OECD today announced that Bosnia and Herzegovina . . .

Europe

UK tax authority scrutiny of Airbnb intracompany transactions may lead to litigation, company says: James Graham / BBC News→

October 30, 2019

Digital Economy

Vestager says Europe should have its own digital tax if global agreement fails, praises countries that adopt unilateral measures: Laura Kayali, Simon Van Dorpe, & Thibault Larger / Politico→

October 30, 2019

Africa

EU Parliament approves public country-by-country reporting resolution

October 30, 2019

Members of the European Parliament on October 24 adopted a resolution urging . . .

Europe

Jim Harra permanently appointed HMRC secretary and chief executive: Beckie Smith / Civil Service World→

October 29, 2019

Bulgaria

EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to Gibraltar companies from withholding tax

October 28, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses a European Court of Justice Advocate General opinion concerning a Bulgarian law that excludes from the exemption from withholding taxes dividends paid by subsidiary companies incorporated in a Member State to their parent companies incorporated in Gibraltar . . .

Africa

OECD’s Pillar One proposal could be first step toward shift in taxing rights to destination countries: Michael Devereux / University of Oxford→

October 23, 2019

Africa

Estimating reliable transfer pricing profit indicators requires use of all available data

October 23, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that the arm’s length argument of many transfer pricing reports is weak because the sample is not random and the sample size of three-year data points is too small . . .

Europe

Ireland publishes tax guidance on tie-breaker rule for dual resident companies

October 23, 2019

Irish Tax and Customs on October 8 published new tax guidance which describes . . .

Digital Economy

Italy’s Council of Ministers make last-minute changes to draft of Budgetary Law 2020

October 23, 2019

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland, writes about Italy’s Budget Plan 2020 and related measures, passed by the Council of Ministers with last-minute changes, which includes a digital services tax, environmental and sugar taxes, and measures to thwart tax evasion . . .

Europe

Ireland’s Finance Bill would update transfer pricing rules, adopt anti-hybrid tax provisions

October 23, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Finance Bill 2019, published October 17, which includes several provisions affecting multinational enterprises including new OECD-compliant transfer pricing documentation rules . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Europe

First Look: Ireland publishes finance bill with international tax and transfer pricing changes

October 17, 2019

The Irish government today published Finance Bill 2019, which contains legislation . . .

Americas

US could still retaliate in response to French digital tax despite earlier suggestions of compromise: Bloomberg Tax→

October 17, 2019

Belgium

Belgian Council of Ministers approves law on reporting of cross-border tax schemes and exchange of information with EU states: Belgium government→

October 17, 2019

Europe

Luxembourg 2020 Budget requires all older tax rulings to expire

October 16, 2019

Danny Beeton, Of Counsel at Arendt & Medernach, Luxembourg and London discusses Luxembourg’s Budget Bill, published on October 14. . .

Digital Economy

Italy still plans to implement 3 percent “web tax” on large digital firms in 2020, minister says: Giuseppe Fonte / Reuters→

October 15, 2019

Europe

Guernsey sets out additional information required on tax return to establish economic substance: States of Guernsey Revenue Service→

October 15, 2019

Digital Economy

German legislation imposing VAT liability on online platforms is contrary to EU law, Commission asserts

October 15, 2019

The EU Commission on October 9 asked Germany to withdraw VAT changes . . .

Africa

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

October 10, 2019

Davide Anghileri of the University of Lausanne, Switzerland, resolutions relating to taxation adopted by the of the EU Council today . . .

Europe

Ireland Budget 2020 released

October 10, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Budget 2020 measures, released by the government on October 8 . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Africa

EU Code of Conduct Group proposes changes to tax blacklist for seven countries including Switzerland, UAE, Mauritius

October 8, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses October 4 EU Code of Conduct Group (Business Taxation) recommendations for amendments to the EU list of non-cooperative tax jurisdictions . . .

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