Europe

Asia-Pacific

India, Netherlands negotiating tax treaty amendment to plug share transfer loophole: Gireesh Chandra Prasad / LiveMint→

April 10, 2019

Europe

Intragroup IP transfer was undervalued for tax purposes, Norway appeals court rules

April 2, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss an interesting March 19 Norwegian appellate court decision which concluded that the “relief from royalty” valuation method should not have been used to determine the value of an intangibles transfer in a merger and acquisition transaction involving Dynamic Rock Support AS . . .

Asia-Pacific

Dyson to move its headquarters from UK to Singapore, claims tax reduction will be “negligible”: Michael Pooler & Jim Pickard / Financial Times→

January 22, 2019

Europe

Irish tax take unexpectedly surges 20 percent as multinationals transfer assets there: Eoin Burke-Kennedy & Pat Leahy / New Irish Times→

December 10, 2018

The Government is on course to run a budget . . .

More: New York Times,

Digital Economy

UK seeks feedback on design of new digital services tax

November 8, 2018

The UK today launched a consultation seeking feedback on the design of its . .

Europe

Ukraine publishes draft tax and transfer pricing law to implement BEPS provisions

October 29, 2018

Ukraine’s Ministry of Finance and the National Bank of Ukraine have published a draft amendment to the tax code designed to implement international tax and transfer pricing provisions . . .

Africa

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

October 26, 2018

African countries that signed tax treaties with Mauritius and other nations considered to be “investment hubs” did . . .

Americas

OECD, EU require Barbados to remove ring-fenced international tax regimes by December 31, Prime Minister says: Katrina King / Barbados Today→

August 27, 2018

Austria

Kerim Keser joins Duff & Phelps’ European transfer pricing practice

June 13, 2018

Kerim Keser is the new head of Duff & Phelps’ German, Swiss, and Austrian transfer pricing practice, the firm announced . . .

Americas

UK reverses support for EU interim digital tax fearing US retaliation, sources say: Bjarke Smith-Meyer / Politico→

April 29, 2018

Europe

Netherlands reveals plan for new withholding tax regime, increased substance requirements

March 5, 2018

Jian-Cheng Ku and Tim Mulder of DLA Piper, Amsterdam, discuss new Dutch government proposals for a conditional withholding tax on royalties, interest, and dividends and increased substance requirements for Dutch holding, license, and financing companies . . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

Denmark

Denmark finance minister endorses global minimum tax for multinational groups, common tax base

March 4, 2019

Denmark’s ruling party, Venstre, supports the global adoption of a minimum tax on multinational group profits, Denmark’s finance minister said on March 3. The minister also . . .

Digital Economy

Germany studying 15 percent withholding tax on foreign online advertising revenue: Reuters→

February 19, 2019

Europe

EU Advocate General addresses deductibility of subsidiary losses in context of merger

January 28, 2019

Davide Anghileri of the University of Lausanne discusses the ECJ Advocate General’s January 10 opinion in the Memira Holding case which concerns the notion of final losses in the context of a merger . . .

Europe

Updated UK-Guernsey tax treaty enters into force

January 22, 2019

A new comprehensive tax treaty and protocol signed by the UK and Guernsey has entered into force, the UK . . .

First Look: EU investigating Netherlands tax rulings granted to Nike for state aid violations

January 10, 2019

The European Commission today announced that it has opened in-depth investigations into tax . . .

Algeria

Goldman Sachs and Cargill lose UK tax avoidance case involving Jersey company structure: Sophie Perryer / European CEO→

October 25, 2018

Europe

What Ireland’s finance bill means for multinational group taxation

October 23, 2018

Aisling Donohue a partner, with Andersen Tax, Dublin, analyzes the effect of Ireland’s October 18 finance bill on MNEs, focusing on changes to exit tax, CFC rules, income tax relief for investments, and tweaks to provisions on the amortization of intangibles . . .

Asia-Pacific

New Japan-Spain tax treaty signed

October 17, 2018

Japan and Spain have signed a new tax treaty, the . . .

Denmark

Denmark bill implementing EU ATAD proposes new rules for CFCs, interest, exit tax, GAAR, hybrids: EY→

October 4, 2018

French minister proposes “sunset clause” for digital services tax at informal ECOFIN meeting: Luxembourg Times→

September 10, 2018

Europe

UK votes to remain outside EU VAT system after Brexit: Avalara VATLive→

July 18, 2018

Danish tax law denying cross-border loss relief is invalid, EU court rules

June 18, 2018

Davide Anghileri of the University of Lausanne discusses a June 12 decision of the EU Court of Justice which concludes that a Danish law that precludes the deductibility of final losses incurred by a foreign permanent establishment violates EU law . . .

Europe

Netherlands proposes temporary changes to tax consolidation regime to comply with EU law

June 13, 2018

Jian-Cheng Ku and Tim Mulder, DLA Piper, Amsterdam discuss a Netherlands Ministry of Finance legislative proposal published June 6 that contains emergency measures to bring the Dutch tax consolidation regime in line with EU law . . .

Europe

Ireland sets out plan to exchange info with other EU States on private tax rulings signed with multinationals

May 7, 2018

Irish Revenue, on May 7, updated its tax guidance to include its plan to implement an EU directive requiring governments to automatically exchange information with other EU States about the private cross-border tax rulings and advance pricing agreements they sign with multinational . . .

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Europe

Irish tax authority clarifies transfer pricing rules for low-value intra-group services

March 19, 2018

Irish Revenue on March 15 provided new guidance taxpayers on Ireland’s simplified transfer pricing approach to low-value intra-group . . .

Europe

Ireland updates tax rules on capital allowances for intangible assets

February 5, 2018

Irish Tax and Customs on February 2 updated its tax and duty manual to reflect changes made in Finance Act 2017 that limit capital allowances for intangible assets plus deductions for related . . .

Europe

Commission publishes opening decision in Huhtamäki state aid probe

May 7, 2019

The EU Commission on May 3 published . . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Europe

EU Advocate General clarifies when sub-subsidiary losses are final for tax deduction

January 18, 2019

Davide Anghileri of the University of Lausanne discusses the EU Advocate General’s January 10 opinion in the Holmen case . . .

Europe

Romania finance minister proposes tax on bank assets at a rate based on interbank ROBOR interest rates, (expected levy would be .9 % from Jan. 2019): Sorin Melenciuc / Business Review→

December 19, 2018

The Romanian government follows in . . .

More: Bloomberg, Reuters, See News.

Switzerland to end special tax allocation practices for new principal companies, finance branches

November 27, 2018

The Swiss government on November 14 announced that it will end special taxpayer-favorable allocation rules for new principal companies and Swiss finance branches, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, . . .

Americas

US Treasury Secretary Mnuchin decries “unilateral and unfair” digital tax proposals

October 25, 2018

US Treasury Secretary Steven Mnuchin today issued a statement condemning proposals being floated in the EU and elsewhere . . .

EU Commission’s digital services tax lacks legal basis because it is not an indirect tax, Council paper says: Financial Times / Mehreen Khan→

October 11, 2018

Canada

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

India, Netherlands negotiating tax treaty amendment to plug share transfer loophole: Gireesh Chandra Prasad / LiveMint→

Intragroup IP transfer was undervalued for tax purposes, Norway appeals court rules

Dyson to move its headquarters from UK to Singapore, claims tax reduction will be “negligible”: Michael Pooler & Jim Pickard / Financial Times→

Irish tax take unexpectedly surges 20 percent as multinationals transfer assets there: Eoin Burke-Kennedy & Pat Leahy / New Irish Times→

UK seeks feedback on design of new digital services tax

Ukraine publishes draft tax and transfer pricing law to implement BEPS provisions

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

OECD, EU require Barbados to remove ring-fenced international tax regimes by December 31, Prime Minister says: Katrina King / Barbados Today→

Kerim Keser joins Duff & Phelps’ European transfer pricing practice

UK reverses support for EU interim digital tax fearing US retaliation, sources say: Bjarke Smith-Meyer / Politico→

Netherlands reveals plan for new withholding tax regime, increased substance requirements

EU Parliament adopts controversial report on tax avoidance and evasion

Denmark finance minister endorses global minimum tax for multinational groups, common tax base

Germany studying 15 percent withholding tax on foreign online advertising revenue: Reuters→

EU Advocate General addresses deductibility of subsidiary losses in context of merger

Updated UK-Guernsey tax treaty enters into force

First Look: EU investigating Netherlands tax rulings granted to Nike for state aid violations

Goldman Sachs and Cargill lose UK tax avoidance case involving Jersey company structure: Sophie Perryer / European CEO→

What Ireland’s finance bill means for multinational group taxation

New Japan-Spain tax treaty signed

Denmark bill implementing EU ATAD proposes new rules for CFCs, interest, exit tax, GAAR, hybrids: EY→

French minister proposes “sunset clause” for digital services tax at informal ECOFIN meeting: Luxembourg Times→

UK votes to remain outside EU VAT system after Brexit: Avalara VATLive→

Danish tax law denying cross-border loss relief is invalid, EU court rules

Netherlands proposes temporary changes to tax consolidation regime to comply with EU law

Ireland sets out plan to exchange info with other EU States on private tax rulings signed with multinationals

EU tax on tech firm revenue does not target US companies, Moscovici asserts

Irish tax authority clarifies transfer pricing rules for low-value intra-group services

Ireland updates tax rules on capital allowances for intangible assets

Commission publishes opening decision in Huhtamäki state aid probe

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

EU Advocate General clarifies when sub-subsidiary losses are final for tax deduction

Romania finance minister proposes tax on bank assets at a rate based on interbank ROBOR interest rates, (expected levy would be .9 % from Jan. 2019): Sorin Melenciuc / Business Review→

Switzerland to end special tax allocation practices for new principal companies, finance branches

US Treasury Secretary Mnuchin decries “unilateral and unfair” digital tax proposals

EU Commission’s digital services tax lacks legal basis because it is not an indirect tax, Council paper says: Financial Times / Mehreen Khan→

What the UK’s new transfer pricing and diverted profits tax statistics tell us

Austria to seek consensus on digital tax during EU presidency: The Irish Times→

US can’t intervene in Apple’s European tax dispute, EU’s top court rules