Europe

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty

October 7, 2019

Leopoldo Parada of the University of Turin, Italy, writes about the implications of the EU General Court’s decsion in the Fiat and Starbucks state aid cases . . .

Digital Economy

Italy probing whether infrastructure used by Netflix constitutes a PE: Stuart Thomson / Digital TV Europe→

October 3, 2019

Europe

EU should be ready to act if no digital tax deal is struck by the end of 2020, incoming EU Commissioners say: EU Reporter→

October 2, 2019

Denmark

Denmark joins BEPS multilateral instrument

October 2, 2019

Denmark on September 30 deposited with the OECD its instrument of acceptance . . .

Europe

Jim Harra appointed interim chief of UK tax agency: Beckie Smith / Civil Service World→

October 2, 2019

Americas

Return on assets (ROA) is an unreliable profit indicator

October 2, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that selection of “return on assets” as a profit indicator in transfer pricing can lead to intractable controversy because the term is ill-defined whereas operating profit margin and operating profit markup are more reliable . . .

Europe

Italian Revenue clarifies new reporting option for patent box tax benefit

October 1, 2019

Gian Luca Nieddu, Head of Transfer Pricing and Tax Value Chain at Hager & Partners, Milan area, writes about Italy’s September 9 clarifications to the patent box regime . . .

Europe

Germany publishes revised tax law requiring disclosure of cross-border transactions

October 1, 2019

German tax practitioner Ninja-Antonia Reggelin notes that a draft German law, released September 27, requiring advisors or their clients to disclose information on cross-border transactions and structures to the national tax authorities differs from earlier versions . . .

Europe

Iceland joins BEPS MLI tax pact

September 27, 2019

Iceland on September 27 became a party to the . . .

Asia-Pacific

Hong Kong signs tax treaty with Estonia

September 26, 2019

The Hong Kong government today announced that Hong Kong and Estonia have signed a . . .

Europe

Jersey launches consultation on mandatory disclosure rules: Government of Jersey→

September 26, 2019

Europe

Denmark tax bill clarifies timing rules for transfer pricing documentation

September 25, 2019

Peter S. Andersen, a transfer pricing partner with Questro International, discusses Denmark’s proposed new requirements for transfer pricing documentation which were included in a Denmark Ministry of Taxation draft bill published on September 12 . . .

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

September 24, 2019

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Europe

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

September 24, 2019

Americas

Ireland outlines arguments in Apple state aid case: Ireland Department of Finance→

September 18, 2019

Digital Economy

Ireland will be better off with global tax deal, Saint-Amans says: Eoin Burke-Kennedy / The Irish Times→

September 18, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

EU finance ministers weighing changes to energy taxation

September 18, 2019

EU finance ministers at an informal ECOFIN meeting . . .

Europe

New Zealand, Guernsey sign tax treaty protocol

September 18, 2019

The governments of New Zealand and Guernsey have signed protocol to their tax information . . .

Europe

The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises

September 18, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s 2020 budget and tax plan, presented September 17, which proposes modifications to the taxation of multinational firms . . .

Europe

Netherlands foreign investment fund tax regime may breach EU law, advocate general says

September 17, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Netherlands, discuss a September 5 opinion of the European Court of Justice Advocate General in a dispute involving the availability of Dutch dividend withholding tax refunds for foreign investment funds . . .

Europe

German finance minister endorses public country-by-country reporting of MNE tax information

September 17, 2019

German tax practitioner Ninja-Antonia Reggelin discusses the changing German position on public release of country-by-country reporting data . . .

Belgium

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

September 16, 2019

The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian . . .

Europe

Google settles French tax dispute for €500m (USD 550m): BBC News→

September 16, 2019

Americas

Ireland/Apple appeal of Commission’s 13 billion euro ($14.4 billion) State aid tax case to be heard this week in Europe’s General Court: Foo Yun Chee / Reuters→

September 16, 2019

Armenia

Armenia approves ratification of Armenia-Denmark double tax treaty: ARMENPRESS→

September 12, 2019

Europe

EU to consider hiking taxes on polluting energy products, ending air and sea transport tax exemptions confidential paper says: Francesco Guarascio / Reuters→

September 11, 2019

Europe

Switzerland: Zurich approves cantonal tax reform

September 11, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses tax reform provisions approved by the canton Zurich’s tax on September 1 . . .

Europe

Guernsey proposes introduction of limited liability companies: Jenna Lomax / Captive Insurance Times→

September 10, 2019

Europe

Margrethe Vestager, proponent of EU state aid tax probes, reappointed Commission competition chief, will also lead digital policy: Mark Scott / Politico→

September 10, 2019

Americas

US-Luxembourg tax treaty protocol enters into force

September 9, 2019

A new protocol to the US-Luxembourg treaty entered into force . . .

Asia-Pacific

Americas

Canada and Switzerland deposit BEPS MLI ratification documents with OECD

August 29, 2019

Canada and Switzerland have deposited their instruments of ratification for the . . .

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

Europe

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty

Italy probing whether infrastructure used by Netflix constitutes a PE: Stuart Thomson / Digital TV Europe→

EU should be ready to act if no digital tax deal is struck by the end of 2020, incoming EU Commissioners say: EU Reporter→

Denmark joins BEPS multilateral instrument

Jim Harra appointed interim chief of UK tax agency: Beckie Smith / Civil Service World→

Return on assets (ROA) is an unreliable profit indicator

Italian Revenue clarifies new reporting option for patent box tax benefit

Germany publishes revised tax law requiring disclosure of cross-border transactions

Iceland joins BEPS MLI tax pact

Hong Kong signs tax treaty with Estonia

Jersey launches consultation on mandatory disclosure rules: Government of Jersey→

Denmark tax bill clarifies timing rules for transfer pricing documentation

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

Ireland outlines arguments in Apple state aid case: Ireland Department of Finance→

Ireland will be better off with global tax deal, Saint-Amans says: Eoin Burke-Kennedy / The Irish Times→

France joins ICAP pilot to jointly assess MNE tax positions

EU finance ministers weighing changes to energy taxation

New Zealand, Guernsey sign tax treaty protocol

The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises

Netherlands foreign investment fund tax regime may breach EU law, advocate general says

German finance minister endorses public country-by-country reporting of MNE tax information

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

Google settles French tax dispute for €500m (USD 550m): BBC News→

Ireland/Apple appeal of Commission’s 13 billion euro ($14.4 billion) State aid tax case to be heard this week in Europe’s General Court: Foo Yun Chee / Reuters→

Armenia approves ratification of Armenia-Denmark double tax treaty: ARMENPRESS→

EU to consider hiking taxes on polluting energy products, ending air and sea transport tax exemptions confidential paper says: Francesco Guarascio / Reuters→

Switzerland: Zurich approves cantonal tax reform

Guernsey proposes introduction of limited liability companies: Jenna Lomax / Captive Insurance Times→

Margrethe Vestager, proponent of EU state aid tax probes, reappointed Commission competition chief, will also lead digital policy: Mark Scott / Politico→

US-Luxembourg tax treaty protocol enters into force

Czech finance ministry to introduce 7 percent digital tax beginning mid-2020: Reuters→

Sweden to introduce bank tax: Reuters→

Ireland proposes sweeping changes to transfer pricing laws

Poland abandons digital service tax after US VP visit: polandin.com→

Germany eyes cutting corporate rate to 25 percent: Birgit Jennen / Bloomberg→

UK raises four pleas before CJEU in appeal of Commission’s state aid decision on CFC rules: KPMG United Kingdom→

US announces entry into force dates for new tax treaty protocols with Japan and Spain

Canada and Switzerland deposit BEPS MLI ratification documents with OECD