Europe
Tax agreements between Hong Kong and Nordic countries enter into force
Hong Kong’s Inland Revenue Department on March 2 announced the entry into force of tax information exchange agreements with Denmark, the Faroe Islands, Iceland, Norway, Sweden, and . . .
EU Code of Conduct Group’s tax work will address non-cooperative jurisdictions, patent box
The EU Code of Conduct Group will focus on addressing non-cooperative, non-EU, tax jurisdictions; monitoring EU implementation of the modified nexus approach for patent boxes; and assessing EU countries’ standstill and rollback of harmful tax measures, according to its work plan, released February 15, writes Davide Anghileri, University of Lausanne . . .
EU finance ministers blast US international tax reform proposals
Finance ministers from Italy, Germany, France, the UK, and Spain have written to US Treasury Secretary Steven Mnuchin warning that provisions in the US tax reform bill contravene the US’s tax treaty and World Trade Organizations (WTO) obligations as well as international agreements reached under the OECD/G20 base erosion profit shifting (BEPS) plan. The ministers – Italy’s Pier Carlo Padoan, Germany’s . . .
EU court resolves tax treaty dispute between Germany, Austria regarding financial instrument
The European Court of Justice (ECJ), in a ruling released September 12, has concluded that the ECJ has jurisdiction to resolve a dispute between Member States which relates to the subject matter of the Treaties of the European Union if the dispute is submitted under a special agreement between the parties, writes Davide Anghileri of the University of Lausanne. . .
Japan, Iceland agree to tax treaty
Japan and Iceland have agreed in principle to tax treaty, the Japanese government . . .
US FATCA IGAs with UAE, Portugal, Croatia, Montserrat enter into force; IGAs signed with Anguilla, Greenland
US Treasury has announced on its website that FATCA intergovernmental agreements (IGAs) have entered into force with the UAE, Portugal, Croatia, Montserrat and that IGAs . . .
UK-Uruguay tax treaty enters into effect
The new UK-Uruguay tax treaty has entered into effect, the UK’s Foreign & Commonwealth Office announced . . .
Switzerland consults on introducing automatic exchange of tax information with 22 countries
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
EU Code of Conduct Group to assess EU tax regimes using modified nexus, adopt BEPS transfer pricing rules
On 17 November, the EU Code of Conduct Group published a report on the work done by a subgroup during the Slovak Presidency on the clarification of the third and fourth criteria (i.e., substance and internationally accepted principles) of . . .
Ireland eases process to claim withholding tax exemption for patent royalties paid for nonresident companies
Irish Tax and Customs has amended its tax guidance to make it easier for companies to an claim an exemption from withholding for . . .
Dutch Tax Plan 2017: what will change for business?
Wiebe Dijkstra and Peter Spijker of De Brauw Blackstone Westbroek, Amsterdam, discuss tax changes in the Netherlands government’s 2017 Budget that affect multinational businesses, international investors, and investment funds . . .
US and Ireland commence tax treaty renegotiation: what could change
Steptoe & Johnson LLP partner, Amanda Varma, discusses the recent announcement that the US and Ireland are renegotiating their tax treaty, and identifies provisions in the existing US-Ireland tax treaty that the US will likely try to modify . . .
Tax treaty requires Netherlands to extend fiscal unity regime to Dutch companies owned by foreign parent, court rules
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a Dutch Court of Appeal decision which requires the Netherlands to extend its fiscal unity-regime to Dutch companies that have foreign parents resident in Israel or resident in countries that have a tax treaty with a nondiscrimination clause similar to that in the Netherlands/Israel tax treaty. . .