Europe
Switzerland, Kosovo sign tax treaty
Switzerland and Kosovo on May 26 signed a tax treaty, agreeing to reduce withholding tax on dividends and royalties, the Swiss government has . . .
UK country-by-country reporting guidance published
The UK’s HM Revenue & Customs (HMRC) today published a policy paper titled “Amendments to Country By Country reporting 2017” and an updated policy. . .
No withholding tax exemption for dividends paid to Dutch UCITS parent, court rules
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
Jeremy Cape joins Squire Patton Boggs, London
Squire Patton Boggs has today announced that UK international and Africa tax expert, Jeremy Cape, has joined the firm as a partner. Cape will join the firm’s Tax Strategy . . .
Italian tax agency issues first investment ruling, addresses logistics hubs
Davide Anghileri of the University of Lausanne discusses Italy’s January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
Hong Kong and Belarus sign tax treaty, text available
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus signed a tax treaty on . . .
Germany proposes tax deduction limits on royalties paid to related companies
Berlin-based tax specialist Ninja-Antonia Reggelin discusses a draft German law published in late December by the finance ministry which is designed to counter harmful foreign country tax practices through the disallowance of tax deductions for royalty payments made to related companies. . .
Australia-Germany tax treaty enters into force
A tax treaty signed between Australia and Germany entered into force on December 7, Australia’s . . .
Belgium’s “fairness tax” conflicts with Parent-Subsidiary Directive, EU court advisor argues
Belgium’s fairness tax is incompatible with the EU Parent-Subsidiary Directive, Juliane Kokott, Advocate General of the Court of Justice of the European Union (CJEU), concluded in an opinion issued today. Under a 2013 . . .
Switzerland to propose tax break for multinational banks
Switzerland’s Federal Council, on September 30, directed its finance ministry to write tax rules to facilitate accumulation of capital by large multinational banks, reducing the tax burden associated with issuing certain financial instruments to group members, writes Davide Anghileri, a PhD researcher and lecturer, University of Lausanne, Switzerland . . .
Ireland granted Apple illegal state aid through tax rulings sanctioning stateless income, EU says
The European Commission on August 30 announced it has concluded that Ireland granted Apple about €13 billion (USD 14.5 billion) in illegal state aid by issuing tax rulings to the company that inappropriately lowered its tax liability in 2003–2014. To restore fair competition, Apple must repay the aid to plus interest, the Commission said. The determination comes after a two year investigation . . .
More:
Apple CEO calls state aid decision “political crap”: Los Angeles Times→
Obama to address Apple decision at G20: AP→
Irish Cabinet agrees to appeal Apple decision: RTE News→
Latvia and Cyprus sign tax treaty
Latvia and Cyprus have signed a tax treaty, Latvia’s Ministry of Finance announced . . .
Iceland and UAE sign tax information exchange agreement
Iceland has signed a tax information exchange agreement with the UAE, completing an effort to sign such agreements with low-tax countries . . .
Leaked EU anti-tax avoidance directive includes interest deduction limits, GAAR, exit tax
A proposed EU anti-tax avoidance directive, to be presented this month by the European Commission, will include rules limiting interest deductibility, a general antiabuse rule (GAAR), controlled foreign company rules, hybrid mismatch . . .