Europe

Americas

House Ways and Means lawmakers urge US response to France’s digital tax proposal

June 20, 2019

US House Ways and Means Committee members . . .

Digital Economy

On turnover-based taxes and digital taxes: the EU Advocate General’s opinion in Vodafone

June 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses an EU Advocate General’s opinion issued June 13 addressing Vodafone’s challenge to the Hungarian telecommunication tax . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

Europe

Netherlands draft tax law targeting hybrid mismatches includes new documentation requirement

July 7, 2019

Mehdi el Manouzi and Michiel Moison of PwC Netherlands discuss the Dutch government’s July 2 legislative proposal implementing the EU rules targeting hybrid mismatches . . .

Europe

EU directive on tax dispute resolution enters into force

July 1, 2019

New rules aimed at resolving cross-border tax disputes . . .

Europe

Guernsey proposes amendments to economic substance, tax residency rules

June 20, 2019

The Guernsey Revenue Service on June 17 announced proposed changes to the economic substance regulations for tax residency. The . . .

Europe

UK tribunal reverses controversial decision on Jersey companies’ tax residency under central management and control test

June 13, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss an important UK tribunal decision addressing the central management and control test for tax residency . . .

Europe

UK opens consultation on insurance premium tax avoidance, fee manipulation: Matt Sheehan / Reinsurance News→

June 6, 2019

Africa

Switzerland’s Federal Council approves plan to exchange account data with 19 more country tax administration

May 30, 2019

Davide Anghileri of the University of Lausanne writes that Switzerland’s Federal Council adopted a dispatch yesterday approving the introduction of automatic exchange of financial account information with 19 more countries . . .

Austria

EU loss in Polish State aid case may be a win for digital services tax

May 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses a May 16 EU General Court decision in Poland v. Commission which could have implications for the legality, under EU State aid rules, of unilateral European digital services tax measures . . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

US MNEs reversing inversions, less likely to invert in the first place, because of 2017 tax changes: Richard Rubin & Jared S. Hopkins / WSJ→

August 1, 2019

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Europe

Dutch government to promote EU-wide carbon pricing, aviation taxes at two-day conference: Netherlands government→

June 20, 2019

American Samoa

Dominica removed from the EU tax blacklist

June 17, 2019

The Council of the EU on June 14 removed Dominica from the . . .

Europe

Malta publishes new rules for consolidated groups: Government Gazette of Malta→

June 10, 2019

Europe

Italy clarifies interaction of patent box regime and foreign tax credit

June 10, 2019

Davide Anghileri of the University of Lausanne discusses clarifications made by the Italian revenue agency on May 28 concerning the interaction of the Italian patent box regime the foreign tax credit. . .

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

American Samoa

EU Council revises tax blacklist, plans less frequent list updates

May 17, 2019

Davide Anghileri of the University of Lausanne discusses today’s decisions by the EU Council regarding the EU list of non-cooperative tax jurisdictions . . .

Europe

Multilateral tax treaty to enter into force for Norway

July 29, 2019

The OECD today announced that Norway has deposited its instrument . . .

Europe

UK Finance Bill 2019-20: what international businesses need to know

July 17, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss selected provisions in draft legislation and explanatory notes to the UK Finance Bill 2019-20 published on July 11 including the UK’s proposed digital services tax . . .

Europe

EU Commission’s publishes decision to probe whether Netherlands tax rulings granted State aid to Nike

July 5, 2019

The EU Commission this week released. . .

Europe

EU court addresses legality of progressive turnover taxes

June 30, 2019

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid discusses a June 27 EU General Court opinion annulling an EU Commission decision on the compatibility of the Hungarian advertisement tax with the EU State aid rules . . .

Americas

Corporate veil dropping: British crown dependencies make beneficial ownership registers public, US takes baby steps

June 24, 2019

Virginia La Torre Jeker, J.D., a US tax practitioner located in Dubai, discusses June 19 announcements of Jersey, Guernsey, and the Isle of Man about plans to make beneficial ownership registers for legal entities public and US legislation proposed June 11 in this area . . .

Europe

Netherlands proposes four options for revising corporate tax group regime

June 20, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a June 17 consultation launched by the Dutch State Secretary of Finance outlining possible approaches for a new corporate tax group regime in the Netherlands . . .

Ten EU states considering German plan for .2% tax on purchases stock in EU headquartered companies: Reuters→

June 17, 2019

Europe

German cabinet passes R&D tax incentive

May 23, 2019

German practitioner Ninja-Antonia Reggelin notes that the German cabinet passed a bill introducing a new tax incentive for research and development (R&D) on Wednesday . . .

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

Digital Economy

French National Assembly and Senate conference committee reaches agreement on digital services tax: French Senate (in French)→

June 30, 2019

Americas

In letter, US Senators Grassley and Wyden urge Treasury to use “all available tools” including Section 891, to stop France from enacting a DST: US Senate Committee and Finance→

June 24, 2019

Europe

France to end 1 billion Euros of business tax breaks to finance personal income tax relief, minister says: Reuters→

June 19, 2019

Europe

Netherlands announces tax policy agenda for 2019

June 12, 2019

Jian-Cheng Kua and Rhys Bane of DLA Piper, Netherlands, discuss the Dutch government’s May 29 announcement of priorities and timelines in the area tax policy . . .

Europe

Swiss corporate tax reform approved by popular referendum

May 19, 2019

Davide Anghileri of the University of Lausanne writes about Switzerland’s corporate tax reform, approved by a popular referendum on Sunday, May 19 . . .

Americas

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

July 23, 2019

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved. . .

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Europe

French DST passed by Parliament clarifies location of users

July 15, 2019

Pascal Luquet of Grant Thornton Société d’Avocats discusses the details of the final version of the French digital services tax, adopted by French Parliament on July 11 . . .

Asia-Pacific

Iraq, Netherlands sign tax treaty: Sangar Ali / Kurdistan24→

July 1, 2019

Americas

US Senate to consider Chile, Hungary, Poland, Japan, Luxembourg, Switzerland tax treaty protocols: Bloomberg Tax→

June 18, 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

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