Europe

Americas

French Senate passes digital service tax despite US threat of potential retaliation, bill likely signed by Macron within two weeks: Liz Alderman / The New York Times→

July 11, 2019

Americas

OECD releases transfer pricing country profiles for Chile, Finland, Italy; updates Colombia, Israel profiles

June 18, 2019

The OECD today released new transfer pricing country profiles for . . .

Europe

Switzerland, Ireland sign protocol amending tax treaty

June 13, 2019

Switzerland and Ireland today signed a protocol to their tax treaty adding . . .

Asia-Pacific

Japan, Finland to negotiate tax treaty amendments

May 21, 2019

The governments of Japan and Finland will . . .

Switzerland, South Korea sign tax treaty protocol

May 17, 2019

Switzerland and South Korea today signed a protocol to their 1980 tax treaty adding . . .

Europe

Italy amends patent box regime, adopts other tax reforms

May 9, 2019

Davide Anghileri of the University of Lausanne discusses a new package of Italian tax measures which include amendments to Italy’s patent box regime and an asset basis step-up on certain mergers, division, or contributions . . .

Cyprus

Cyprus Finance Minister drops proposal to increase corporate tax rate from 12.5 to 15 percent following business outcry: Bouli Hadjioannou / in-Cyprus→

August 7, 2019

Europe

EU Commission says Greece must allow deductions for foreign losses

July 30, 2019

The EU Commission has charged that Greece’s tax treatment of losses incurred . . .

Africa

OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia

July 17, 2019

The OECD on July 5 requested taxpayer feedback on the tax treaty dispute . . .

Europe

EU court rules on deductibility of losses of sub-subsidiary, losses transferred through merger

June 24, 2019

Davide Anghileri of the University of Lausanne discusses two ECJ decisions released June 19 addressing when EU States are required by EU law to allow a parent company to deduct in Sweden final losses of a group member; one case involved losses of a sub-subsidiary located in Spain and the other of a Germany subsidiary later merged into its Swedish parent . . .

French court reaches surprising conclusions on cost plus transfer pricing method

June 6, 2019

Terence Wilhelm of Cara Avocats, France, discusses a French case, Labs France, where the court addressed the treatment of taxes for purposes of the cost plus transfer pricing method . . .

Europe

Shell reveals that only one of its subsidiaries paid tax in Netherlands where the group is headquartered, prompting calls for tax avoidance hearing: Reuters→

May 21, 2019

Americas

France should renegotiate FATCA unless US agrees to concessions aiding dual nationals, parliamentary report says: Gregory Viscusi / Bloomberg→

May 16, 2019

Europe

Ireland should “engage constructively” on digitalization, tax avoidance to safeguard reputation, IMF says: International Monetary Fund→

May 14, 2019

Digital Economy

EU leaders to discuss tax priorities at summit

May 8, 2019

The EU Commission has prepared a paper in advance of a May 9 EU leaders meeting which . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Europe

Ireland Budget 2019 announces new taxes on assets shifted offshore

October 9, 2018

As a part of Ireland’s commitment to implement the EU Anti-Tax Avoidance Directive, Ireland’s Finance Bill will provide for new exit tax . . .

Europe

Proposed changes to Ireland’s transfer pricing regime could affect UK interest-free lending structures: KPMG→

September 24, 2018

Europe

Russian customs proposes to impose duty on all imports of goods sold by foreign online stores by 2020: Crime Russia→

June 18, 2018

EU puts public country-by-country reporting of tax data back on the agenda

June 14, 2018

After several quiet months, it seems that consideration of an EU Commission proposal for public country-by-country reporting is now moving forward . . .

Europe

Germany suspends interest charge on late tax payments providing relief for MNEs

May 16, 2018

Ninja-Antonia Reggelin discusses the German Federal Fiscal Court’s May 14 announcement that it will suspend a law imposing large interest charges on unpaid taxes because the law may be unconstitutional . ..

Switzerland focusing on resolving disagreements over Tax Proposal 2017, which will likely be resolved, after that, attention will turn to taxation of digital economy, Oberson says: CNN Money Switzerland

April 20, 2018

Digital Economy

UK digital services tax would apply to about 30 entities, HM Treasury officials say: KPMG→

May 8, 2019

Europe

Dutch parliament committee to “forcefully” ask Shell to attend tax avoidance hearing: Reuters→

April 10, 2019

Europe

Slovakia tax on food retail sector under EU investigation for illegal state aid

April 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland, notes the European Commission’s April 2 announcement of an in-depth state aid investigation into tax exemptions provided in Slovakia’s tax on the food retail sector . . .

Europe

First Look: Germany, Netherlands release joint statement on tax avoidance, minimum tax: Netherlands Ministry of Finance→

March 27, 2019

MNE Tax will publish an in-depth article about this development shortly.

Croatia

Taxation of interest between associated parties: the Croatian view

March 25, 2019

Ksenija Cipek, Assistant Director General for Tax Legislation and International Cooperation at the Ministry of Finance in Croatia, discusses new developments in Croatia concerning the tax treatment of interest between associated parties . . .

Europe

Ireland seeks feedback on proposed transfer pricing revisions

February 19, 2019

Ireland’s Department of Finance of February 18 opened a consultation on proposed changes to the transfer pricing laws . . .

Europe

Nike tax rulings under EU Commission scrutiny

January 11, 2019

Dr. Patricia Lampreave, an EU tax and state aid expert and professor at the Instituto de Estudios Bursátiles, Madrid, discusses the EU Commission’s announcement yesterday of an investigation into tax rulings granted by the Dutch tax authorities to Nike group companies . . .

Switzerland’s Tax Proposal 17 approved

October 9, 2018

Davide Anghileri of the University of Lausanne, provides an update of the status of Switzerland’s tax reform initiative, Tax Proposal 17 . . .

Europe

Danny Beeton joins Arendt & Medernach’s transfer pricing practice

May 23, 2018

Arendt & Medernach has announced that transfer pricing specialist Danny Beeton has joined the firm working in both London and Luxembourg. Beeton is formerly with Duff and Phelps, London. His role at . . .

Apple pays Ireland 1.5 billion euros (USD 1.76 billion) in escrow toward 13 billion tax bill in State aid dispute: Reuters→

May 22, 2018

Americas

UK says US-based MNEs underpaid GPB 4.6 billion (USD 5.9 billion) of UK tax last year: Out-law.com→

April 24, 2019

Switzerland to exchange country-by-country reports on multinationals with more countries

October 26, 2018

Switzerland’s Federal Council, during its meeting of October 17, decided to extend the exchange of country-by-country on multinationals to additional countries, writes Davide Anghileri, University of Lausanne . . .

Europe

UK guidance addresses effect of “no-deal” Brexit on VAT system

September 24, 2018

UK HM Reveue and Customs (HMRC) has issued a guidance note that discusses the VAT implications . . .

MEP asks EU Commission to investigate whether Shell/Netherlands merger deal avoiding dividend tax was EU State aid: DutchNews.nl→

June 18, 2018

Europe

Finland to terminate tax treaty with Portugal, government warns

June 13, 2018

Finland’s government will notify Portugal on June 14 that it will terminate the 1970 . . .

Europe

Italy issues draft tax regulations on arm’s length standard, corresponding adjustments

February 22, 2018

Italy’s Ministry of Economy and Finance on February 21 released for public consultation draft regulations designed to align Italy’s transfer pricing rules with the outcome of Actions 8–10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, writes Davide Anghileri, University of Lausanne . . .

Europe

Amazon settles French tax dispute over income allocation for undisclosed sum: Reuters→

February 5, 2018

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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