Europe
Japan, Slovenia sign treaty to reduce tax on cross-border income
Japan and Slovenia today signed their first tax treaty, Japan’s Ministry of Finance has . . .
More tax rulings under EU scrutiny for illegal state aid, Vestager says
The European Commission is scrutinizing advance pricing agreements (APAs) issued to financing companies and to other businesses for potential state aid violations EU competition commissioner Margrethe . . .
UK government proposes tougher withholding tax rules for royalties paid to nonresidents
Anne Fairpo of Temple Tax Chambers discusses proposed UK tax law changes that would subject more categories of royalty payments to withholding tax . . .
EU to require country-by-country tax reporting, limited public release of data likely
European Union finance ministers today reached political agreement on requiring EU-wide country-by-country reporting by multinational corporations and on sharing that data between tax administrations. It was also revealed today that any future. . .
Switzerland and Canada agree on automatic exchange of financial account information
Switzerland and Canada on February 4 signed a joint declaration to work toward implementing automatic exchange of information on the financial accounts . . .
OECD officials discuss international tax and transfer pricing agenda
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
US IRS reassessing transfer pricing strategy following court losses, unable to sign all country-by-country reporting CAAs
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
EU doubles down on State aid theory, orders Amazon to pay Luxembourg taxes
Dimitrios Kyriazis of the New College of the Humanities and University of Oxford discusses today’s news that the EU Commission has adopted a negative decision in the Amazon fiscal State aid case and the Commission’s argument that a departure from the arm’s length principle amounts to the conferral of an advantage to the recipient . . .
Italian law aims to encourage foreign internet companies to pay more tax
Italian legislation proposed May 22 is designed to increase tax collection from foreign multinationals that have online activities Italy, writes Davide Anghileri of the University of Lausanne . . .
EU court rules company reps may face criminal liability for corporation’s failure to pay tax
The European Court of Justice (ECJ) has ruled that a criminal proceeding can be brought against the legal representative of a company even if the company has already paid a tax penalty with respect to the same act or omission, writes Davide Anghileri of the University of Lausanne . . .
Italy publishes tax rules implementing country-by-country reporting for large multinationals
Davide Anghileri of the University of Lausanne discusses Italy’s new country-by-country reporting requirements for large multinationals . . .
Hong Kong-Romania tax treaty enters into force
Hong Kong’s Inland Revenue Service, on December 9, announced that a new tax treaty with Romania entered into force on . . .
Swiss Federal Council agrees to exchange of country-by-country reports on multinationals
Davide Anghileri of the University of Lausanne discusses the Swiss Federal Council’s adoption on November 23 of the multilateral agreement on the exchange of country-by-country reports and a federal act required for its implementation . . .
Ireland’s Budget 2017 (again) affirms 12.5 percent corporate tax rate, addresses “section 110” firms
Professor James Stewart of Trinity College, Dublin, discusses Ireland’s Budget 2017 and the Minister for Finance’s accompanying address, delivered today, which affirmed Ireland’s intent to maintain a low corporate tax rate and address the taxation of financial intermediaries known as section 110 firms . . .
Japan’s tax treaty with Germany, protocol with India, to enter into force
Japan’s Ministry of Finance today announced that two tax agreements will enter into force: a tax treaty with Germany and a protocol to a tax treaty with India. Notifications . . .
Draft German tax law would allow use of losses on ownership change, boosting venture capital industry
International tax professional, Ninja-Antonia Reggelin, discusses a proposed German law currently under debate that would allow corporations to use losses following a change of shareholders . . .