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Europe

Europe

The new UK “Profit Diversion Compliance Facility”: what MNEs need to know

January 13, 2019

Liz Hughes of Grant Thornton UK LLP discusses the UK’s new “Profit Diversion Compliance Facility,” issued on 10 January, which is designed to encourage groups with arrangements that might fall within the scope of the diverted profits tax to amend their transfer pricing policies . . .

Americas

Google shifted USD 23 billion income to tax haven Bermuda in 2017 using Dutch shell company: Reuters→

January 4, 2019
Europe

Ireland records first budget surplus since crash aided by record collection of €10.4 billion in corporation tax, largely from multinationals: Eoin Burke-Kennedy / The Irish Times→

January 3, 2019
No Picture
Council of the European Union

Germany, France propose stripped-down version of digital services tax 

December 5, 2018

French and German finance ministers on Tuesday presented yet another compromise proposal for an EU-wide digital services tax, this time . . .

No Picture
Europe

New Switzerland-Latvia tax treaty protocol enters into force

October 2, 2018

The Swiss government today announced that a protocol to its 2002 tax treaty with . . .

Europe

Germany aligns tax guidelines on cost sharing arrangements with OECD standards

July 17, 2018

Ninja-Antonia Reggelin discusses the German finance ministry’s July 5 update to its transfer pricing guidelines on cost contribution arrangements between related companies . . . .

No Picture
Europe

Ted Keen to lead Duff & Phelps’s European transfer pricing practice

June 26, 2018

Duff & Phelps has announced that Ted Keen has joined the firm to head its European transfer pricing practice. Keen will be based in London and . . .

Africa

Turkey’s IP tax regime is harmful; new Singapore, Luxembourg, Lithuania, Slovakia laws meet standards, OECD report concludes

May 20, 2018

Turkey’s technology development zone tax regime is harmful to the tax base of other countries while new Singapore, Luxembourg, Lithuania, and Slovakia tax laws favoring intellectual property (IP) are not, a May 17 report prepared by the OECD Forum on Harmful . . .

Americas

Swiss advance information exchange for tax purposes with Singapore, Hong Kong, other financial centres

May 11, 2018

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 . . .

Europe

France and Luxembourg sign new tax treaty following BEPS standards, French case law

March 27, 2018

Terence Wilhelm of Cara-Avocats, Lyon, discusses the new France-Luxembourg tax treaty signed March 20, noting that some features make this treaty one of a kind and may shed light on what future tax treaties signed by France will look like . . . 

Asia-Pacific

Hong Kong, France to exchange of country-by-country reports

January 15, 2018

The government of Hong Kong on January 15 announced that it has entered into an arrangement with France for the automatic exchange of country-by-country (CbC) reports on the tax affairs . . .

No Picture
Europe

EU Advocate General says Germany’s transfer pricing laws are compatible with EU law

December 14, 2017

The Advocate General of the Court of Justice of the European Union, Michal Bobek, on December 14, issued his opinion in an important case under consideration by the court, concluding that Germany’s transfer pricing legislation does not violate EU concepts of freedom . . . .

No Picture
Europe

Finland’s exit tax violates EU law, court rules

November 28, 2017

Davide Anghileri of the University of Lausanne discusses a November 23 decision of the European Court of Court of Justice concluding that Finland’s exit tax violates EU law concepts of freedom of establishment . . . 

Europe

Dutch court puts burden of proof on tax authority in transfer pricing case because taxpayer prepared documentation: Baker McKenzie→

October 20, 2017
No Picture
Europe

Some EU ministers skeptical of tax on digital firms: Joe Kirwin / Bloomberg BNA→

September 19, 2017
Europe

Luxembourg will not immediately oppose EU equalization tax proposal: Luxemburger Wort→

September 14, 2017
Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Belgium

MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland: Loyens & Loeff→

June 15, 2017
Europe

France’s withholding tax on dividends paid to EU subsidiaries violates EU law, Commission says

May 17, 2017

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 . . .

Europe

EU court to review German law denying withholding tax exemption for some dividends paid to foreign parents

April 4, 2017

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 . . .

Europe

New Germany-Switzerland tax arbitration agreement provides legal certainty

March 10, 2017

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. . .  

No Picture
Denmark

EU court to consider beneficial ownership definition for interest and royalty directive

March 7, 2017

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 . . .

Europe

Russia investigates IKEA Germany for tax fraud from stock sale of Russian subsidiary

October 26, 2016

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 . . .

Europe

Irish Finance Minister, in speech, summarizes status of Apple state aid controversy, restates opposition to EU Commission decision: Ireland Department of Finance→

October 6, 2016

See: Statement.

Europe

EU scrutinizing Luxembourg tax rulings on intercompany convertible loans for state aid

September 19, 2016

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 . . .

Asia-Pacific

China, Romania sign tax treaty

September 7, 2016

The Chinese government has announced that China and Romania have signed a tax treaty in an effort to promote investment between . . .

Americas

US, Luxembourg agree to tax treaty changes to prevent double nontaxation

June 23, 2016

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 . . .

No Picture
Europe

EU countries strike deal on anti-tax avoidance directive aimed at multinationals

June 21, 2016

The European Union has reached political agreement on a directive designed to combat multinational corporation tax avoidance, with all 28 countries signing on. . .

Europe

New Dutch guidance addresses dividend withholding tax refund due foreign shareholders

May 5, 2016

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 . . .

Europe

Luxembourg director fees are subject to VAT: Allen & Overy→

March 29, 2016

See: Allen & Overy.

Americas

US has no plans for retaliatory EU tax for state aid decisions, Stack says: Connor Humphries / Reuters→

March 11, 2016

See: Reuters.

Europe

Guernsey publishes MAP guide for resolving cross-border tax disputes

May 6, 2019

The government of Guernsey on April 30 published new guidelines for taxpayers on how to take . . .

Asia-Pacific

Japan publishes ‘synthesized text” of tax treaty with Finland

April 19, 2019

The Japanese government has published on its website the synthesized text of the Japan-Finland . . .

Americas

Bermuda likely to be removed from EU list of non-cooperative jurisdictions, finance minister says: Government of Bermuda→

April 9, 2019
No Picture
Europe

Switzerland and Ukraine sign tax treaty protocol

January 24, 2019

Switzerland and Ukraine today signed a protocol amending . ..

Digital Economy

US pushing for global adoption of minimum tax, revised profit allocation rules

December 17, 2018

The US is seeking worldwide agreement on proposals that would significantly alter the international tax system, aiming to preempt a threatened EU digital services tax and bring stability to the international tax system, Treasury officials said at  . . .

Europe

Jersey advances draft tax law requiring company substance

October 24, 2018

A draft tax law requiring companies to have greater economic activity in Jersey before being considered registered for tax purposes there has been lodged for . . .

Americas

Cayman Islands minister to meet with EU officials about tax blacklist, planning public consultations on new laws requiring substance for tax residence: James Whittaker / Cayman Compass→

September 19, 2018
No Picture
Africa

Swiss Federal Council adopts MLI

August 22, 2018

The Swiss Federal Council on August 22 adopted a dispatch on the Multilateral Convention to Implement Tax Treaty . . .

Posts pagination

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What’s Next

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May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
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RECENT COMMENTS
  • 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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Latest

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Recent Comments

  • 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

R&D Tax Credit News

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Accounting & Reporting News

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  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
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    March 23, 2022

Transfer Pricing News

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    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
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US tax focus

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