Europe

Finland issues transfer pricing rules for intragroup services: KPMG→

October 18, 2017

Denmark

Danish government proposes capital gains tax cut: Julie Astrid Thomsen / Reuters→

August 30, 2017

EU weighing approaches for tax blacklist sanctions, to allow individual State lists: Joe Kirwin / Bloomberg BNA→

August 14, 2017

EU Court of Justice Advocate General concludes Finnish exit tax violates EU law: KPMG→

July 17, 2017

Americas

US seeks to intervene in Apple appeal of EU State aid case, sources say: Diane Bartz / Reuters→

July 4, 2017

Europe

Ernesto Maria Ruffini takes over as head of Italian tax revenue agency

June 15, 2017

Ernesto Maria Ruffini is the new director of Italy’s Tax Revenue Agency as . . .

Europe

Ireland’s tax treaty position on the OECD multilateral instrument

June 15, 2017

Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .

Swedish ruling concludes parent-subsidary directive anti-avoidance rule inapplicable to dividend distribution to Maltese parent: EY→

May 17, 2017

Europe

Carlo Fassbinder appointed Luxembourg Director of Taxation

March 20, 2017

Carlo Fassbinder is Luxembourg’s new Director of Taxation at the Ministry of Finance, Luxembourg’s Ministry of Finance today announced. Fassbinder was previously head of retail and corporate . . .

Americas

Disallowance of US loss from worthless Russian sovereign debt upheld on appeal, purchase lacked substance: Steptoe & Johnson→

March 15, 2017

See: Steptoe & Johnson.

Apple’s tricky argument regarding subs’ income source may not sway EU court, NYU prof says: Daniel Shaviro / Start Making Sense→

February 23, 2017

See: Start Making Sense.

Americas

Tax information exchange agreement between Isle of Man, Turks and Caicos enters into force

December 21, 2016

The Isle of Man government on December 14 announced that an agreement for the exchange of information relating to tax matters with the government . . .

Africa

BRICS country tax officials express support for “inclusive framework” on BEPS

December 6, 2016

Heads of revenue of the BRICS countries – Brazil, Russia, India, China, and South Africa – at a meeting held December 5–6 in Mumbai, expressed support for measures . . .

Europe

Hungary to cut corporate tax rate to 9 percent next year: Jason Karaian / Quartz→

November 26, 2016

See: Quartz. More: RTE, Financial Times

EU Commission proposes to speed resolution of double tax disputes

October 25, 2016

The EU Commission has today released a proposed directive designed to strengthen existing mechanisms to resolve tax disputes between EU countries that result in double . . .

Europe

Luxembourg, Ukraine sign tax treaty protocol

October 6, 2016

Luxembourg and Ukraine have signed a protocol to their 1997 tax treaty, Ukraine’s Ministry of Finance announced . . .

Americas

Brazil adds Ireland, Austria, Curaçao and Saint Martin to tax haven list: Julio Wiziack / Folha de S.Paulo→

September 19, 2016

See: Folha de S.Paulo. More: Reuters. See: Notice.

Europe

New UK law allows government to introduce public country-by-country reporting by multinationals

September 6, 2016

UK tax professional, Tim Law, discusses the implications of a law passed yesterday that gives the government power to require public country-by-country reporting by multinationals . . .

Asia-Pacific

India’s Cabinet approves Belgium/India tax treaty protocol

June 22, 2016

India’s Cabinet has today approved a protocol to its 1993 tax treaty with . . .

EU ministers still can’t agree on anti-tax avoidance directive targeting multinationals

June 17, 2016

EU finance ministers at a June 17 ECOFIN meeting were again unable to reach political agreement on an anti-tax avoidance directive aimed at multinational corporations . . .

Belgium

EU Commission publishes decision concluding Belgium’s excess profits tax scheme is State aid

May 4, 2016

The EU Commission today published a non-confidential version of its decision that Belgium’s excess profits tax scheme is illegal under EU State aid rules. The Commission’s decision, first announced in a press release last . . .

Asia-Pacific

Singapore-Ireland tax treaty MLI amendments enter into effect

May 2, 2019

The Singapore government has announced that amendments made to the Singapore-Ireland tax treaty as a result of . . .

Council of the European Union

Draft German law offers procedures to resolve double tax disputes

April 18, 2019

Tax practitioner Ninja-Antonia Reggelin discusses a German draft law published April 16 providing a scheme for resolving instances of double taxation . . .

Asia-Pacific

Australia publishes synthesized text of tax treaty with Slovak Republic as affected by the MLI: Australian Taxation Office→

April 9, 2019

Europe

Spain, Britian sign Gilbraltar tax treaty: Aaj News→

March 7, 2019

Belgium’s excess profits tax scheme is not State aid, EU court concludes

February 14, 2019

Professor and EU tax and state aid expert, Dr. Patricia Lampreave, discusses today’s European General Court decision annulling an EU Commission decision concerning Belgium’s excess profits tax scheme . . .

Europe

MNEs in EU pay lowest effective tax rate in Luxembourg (2.2 %), highest in Norway (48.7%), study says: EU Parliament, Greens/EFA Group→

January 23, 2019

Bulgaria

Bulgaria tax changes introduce first CFC rules, modify thin cap provisions

December 4, 2018

Ivan Dimitrov discusses important tax changes introduced in Bulgaria last week, including the country’s first-ever controlled foreign company (CFC) rules and revisions to the thin capitalization regime . . .

French minister asks for EU Parliament support on digital services tax: European Parliament→

October 23, 2018

EU Parliament members seek higher tax rate for temporary digital services tax: Samuel Stolton / EURACTIV→

October 11, 2018

Europe

Diageo pays UK £199 million (USD 250 million) in transfer pricing settlement to avoid DPT: Ben Stupples / Bloomberg Tax→

July 30, 2018

Americas

OECD asks MNEs for feedback on cross-border tax dispute resolution in Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania, South Africa

July 26, 2018

The OECD is seeking feedback on multinationals’ experience with cross-border tax dispute resolution procedures in . . .

Europe

UK publishes final MLI reservations and notifications

July 17, 2018

The UK has published its final list of reservations and notifications to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base . . .

Europe

UK to publish draft tax legislation

June 18, 2018

The UK government will publish draft tax changes for its next finance bill on . . .

Americas

New OECD project aims to encourage proper use of tax treaty principal purpose test, official says

June 10, 2018

The OECD is working on a project designed to encourage tax administrations to act reasonably when interpreting and applying the principal purpose test, an official said at the 2018 OECD International Tax Conference, held . . .

Digital Economy

Spain to propose digital services tax beginning 2019

May 9, 2018

The Spanish government has announced it will propose a temporary tax on digital company revenue this year, aiming for the new tax to take effect in 2019, writes Alma Virto. a researcher and PhD candidate at the University of Salamanca, Spain . . .

Swiss Federal Council approves tax agreements with Ecuador and Zambia

April 18, 2018

Switzerland’s Federal Council on April 18 approved a new tax treaty with Zambia and a protocol amending Switzerland’s tax treaty with Ecuador. The new . . .

Europe

Dutch taxation of multinationals: a 2017 year-in-review and look forward to the future

January 8, 2018

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, write that 2017 was a year of significant change for Dutch tax law and international tax law; the authors predict that 2018 will be just as dynamic . . .

Americas

Royalty, interest withholding tax rates drop under Ireland-Chile tax treaty

December 12, 2017

Ireland’s government today announced that withholding tax rates for interest and royalties will drop under the Ireland-Chile tax treaty according to the terms . . .

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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