Europe
Swiss advance information exchange for tax purposes with Singapore, Hong Kong, other financial centres
Davide Anghileri of the University of Lausanne discusses the Swiss government’s progress advancing exchange of financial account information for tax purposes with Singapore, Hong Kong, and several countries, including Bahamas and Bahrain, that apply automatic exchange in a non-reciprocal manner . . .
France’s withholding tax on dividends paid to EU subsidiaries violates EU law, Commission says
The EU Commission today notified France that it considers France’s withholding tax on dividends paid to subsidiaries located in other EU States or European Economic Area (EEA) Members States to be contrary EU law. The Commission said . . .
EU court to review German law denying withholding tax exemption for some dividends paid to foreign parents
The European Court of Justice has published a reference for a preliminary ruling in a case challenging a German law that denies relief from withholding tax on some distributions . . .
New Germany-Switzerland tax arbitration agreement provides legal certainty
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
EU court to consider beneficial ownership definition for interest and royalty directive
The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .
Russia investigates IKEA Germany for tax fraud from stock sale of Russian subsidiary
Russia’s Investigation Committee has again launched a criminal probe alleging that IKEA’s German division committed tax fraud when it failed to pay taxes upon its sale of stock in a Russian . . .
EU scrutinizing Luxembourg tax rulings on intercompany convertible loans for state aid
The European Commission today made it clear that it is not bowing to political pressure to halt its investigation into EU states that grant private tax deals to multinationals, announcing a probe into Luxembourg tax rulings granted to French energy company Engie, formally . . .
China, Romania sign tax treaty
The Chinese government has announced that China and Romania have signed a tax treaty in an effort to promote investment between . . .
US, Luxembourg agree to tax treaty changes to prevent double nontaxation
The US Treasury Department today announced that the US and Luxembourg, during negotiations for new protocol to their 2000 tax treaty, have agreed to provisions to address tax avoidance through triangular and exempt permanent . . .
EU countries strike deal on anti-tax avoidance directive aimed at multinationals
The European Union has reached political agreement on a directive designed to combat multinational corporation tax avoidance, with all 28 countries signing on. . .
New Dutch guidance addresses dividend withholding tax refund due foreign shareholders
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, discuss new Dutch guidance on withholding tax refunds due foreign shareholders following the Dutch Supreme Court’s decision in Miljoen, X, and Société Général . . .