Europe

Switzerland and Netherlands sign protocol amending tax treaty

June 12, 2019

Switzerland and the Netherlands have signed a protocol of amending their tax treaty . . .

Cyprus

Cyprus drafting new transfer pricing law to harmonize with OECD guidelines: Annie Charalambous / In-Cyprus.com→

May 28, 2019

Digital Economy

International tax rules should recognize value creation from scale, brands, market access, Irish Minister says: Reuters→

May 23, 2019

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Denmark

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

July 23, 2019

The Danish tax administration on July 12 published a decree specifying new transfer pricing documentation rules and allowing some transfer pricing cases to be reopened where discretionary assessments were made, write Johnny Bøgebjerg and Henrik Lund of KPMG Acor Tax, Denmark. . . .

Europe

UK launches court challenge to EU Commission’s finding that CFC financing company exemption is state aid: KPMG→

June 24, 2019

Digital Economy

EU court agrees to hear Google Ireland’s challenge to Hungarian digital services tax on advertising: Duff & Phelps Transfer Pricing Times→

June 12, 2019

Asia-Pacific

Switzerland, Iran sign protocol amending tax treaty

June 3, 2019

The governments of Switzerland and Iran have signed protocol amending their . . .

Asia-Pacific

Cyprus, Kazakhstan sign tax treaty: KNEWS→

May 17, 2019

Europe

Incoming European Commission president says tech giants must pay fair share of tax, plans carbon border tax: Bloomberg Tax→

July 22, 2019

Europe

14 MNEs, including Vodafone and GSK, launch court challenge to EU Commission finding of State aid in UK CFC exception: ICAEW Economia→

July 18, 2019

Bosnia and Herzegovina

Bosnia and Herzegovina joins the Inclusive Framework on BEPS

July 11, 2019

The OECD on July 10 announced that Bosnia and Herzegovina has joined the “Inclusive Framework on BEPS” . . .

Europe

Takeaways from Italy’s new transfer pricing country profile

June 28, 2019

Gian Luca Nieddu of Hager & Partners, Milan area, Italy, discusses the latest version of Italy’s transfer pricing country profile, prepared by Italian Central Revenue, published on the OECD webpage a few days ago, which reflects the agency’s latest views on transfer pricing enforcement . . .

Europe

Netherlands establishes expert commission to examine how to make multinational taxation “more fair”: John O’Donnell & Toby Sterling / Reuters→

June 12, 2019

Asia-Pacific

Singapore’s tax treaties with Finland and Guernsey amended by MLI

June 3, 2019

The Inland Revenue Authority of Singapore (IRAS) has announced that amendments to . . .

Albania

Albania signs BEPS MLI

May 28, 2019

Albania on May 28 signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, becoming . . .

Albania

Albania joins Inclusive Framework on BEPS to address multinational tax issues

August 8, 2019

The OECD today announced that Albania . . .

Europe

Germany must recognize other EU States’ profit and loss transfer agreements for tax consolidation, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a letter of formal notice to Germany for refusing to recognize profit and loss . . .

Americas

France seeks to reach digital tax deal with US at August G7 meeting, French minister says: The Local→

July 29, 2019

Europe

Ireland updates CFC tax guidance

July 22, 2019

Ireland today updated its Tax and Duty Manual . . .

Europe

Ireland updates list of countries with which it exchanges information on tax rulings: Tax and Duty Manual Part 35-00-01→

June 10, 2019

Asia-Pacific

Sri Lanka, Denmark to revise tax treaty: Economynext→

June 6, 2019

Americas

Bermuda, Aruba, Barbados set to be removed from EU tax blacklist, EU official says: Reuters→

May 13, 2019

Europe

Switzerland could lose CHF10 billion (USD10.2 billion) tax if global corporate overhaul requires companies to be taxed where sales generated: SWI swissinfo.ch→

July 22, 2019

Europe

Ireland’s Tax Strategy Group releases paper on corporation tax in advance of Budget 2020: Ireland Department of Finance→

July 17, 2019

Belgium

Belgium deposits MLI ratification instrument with OECD

June 27, 2019

Belgium has deposited with the OECD its instrument ratifying . . .

Belgium

Belgium transfer pricing reporting burdens reduced through legislation

June 2, 2019

Geoffroy Galéa of Laga (Deloitte Legal) and Laura Deroy and Florence Siccard of Deloitte, Belgium, discuss new legislation introduced in Belgium on May 15 that decreases in the compliance burden related to the transfer pricing reporting obligations of multinational groups . . .

Europe

Google doesn’t owe French tax on sales to advertisers, court rules

May 23, 2019

Pascal Luquet, Mickaël Duquenne, and Paul Bufort of Grant Thornton Société d’Avocats, Neuilly-Sur-Seine, France, discuss Google’s latest court win in France where the Paris administrative court of appeal confirmed that Google Ireland had no permanent establishment in France and that Google was not taxable in France on Google AdWords sales to French advertisers those years . . .

Belgium

Denmark must adopt EU controlled foreign company tax rules, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

Europe

Gibraltar joins “Inclusive Framework on BEPS” working on multinational group tax issues

July 7, 2019

Gibraltar has joined a coalition of countries working on international tax and transfer pricing issues. . .

Armenia

Armenia, Malta to sign tax treaty: Armenpress→

June 27, 2019

Swiss parliament agrees to eliminate bearer shares to avoid OECD tax blacklist: SWI swissinfo.ch→

June 24, 2019

Europe

Russia joins BEPS MLI to address tax avoidance

June 18, 2019

Russia has joined the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the . . .

Asia-Pacific

Pakistan, Bulgaria sign tax treaty: Faisal Saeed / TechJuice→

May 22, 2019

Europe

Warren Novis to lead BDO Ireland’s transfer pricing unit

May 21, 2019

Warren Novis is BDO Ireland’s new head of transfer pricing, the . . .

Americas

Cayman Island guidance released on economic substance

May 16, 2019

The Cayman Islands government on April 30 . . .

Europe

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

July 22, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a July 12 Netherlands government proposal requiring intermediaries and, in some cases, taxpayers, to report cross-border arrangements that meet certain hallmarks to the tax authorities. . . .

Europe

EU Commission publishes decision finding UK group financing exemption to CFC tax rule is State aid

July 17, 2019

The European Commission has* published the nonconfidential version of its decision concluding that . . .

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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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