Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .
The European Commission has today launched a public consultation on whether the EU should take action to create disincentives for tax advisors and other intermediaries that help taxpayers . . .
Andorra has become the 40th country that is neither an OECD nor G20 member to join what is known as the inclusive framework for BEPS implementation, a group of countries that have pledged to adopt measures, designed by the OECD and G20 in the base. . .
Italy’s tax authorities on September 26 issued a circular clarifying new rules on the deductibility of costs associated with transactions between Italian resident individuals or entities and businesses operating in blacklisted tax haven countries, writes guest author, Davide Anghileri . . .
India and Slovenia have signed a protocol to their tax treaty, agreeing to expand the scope of information exchange between tax authorities. . .
The US and Switzerland have agreed that Swiss bank account owner identities can remain confidential for purposes of the Foreign Account Tax Compliance Act (FATCA) in some instances where the account is held . . .
Davide Anghileri of the University of Lausanne discusses Court of Justice of European Union’s May 31 decision in Hornbach-Baumarkt which concluded that German transfer pricing legislation is valid and found that the role of the parent company as a shareholder of a non-resident company may be taken into account in assessing a non-arm’s length related-party transaction . . .
The European Commission on December 18 opened another State aid investigation into private tax rulings granted by an EU nation to a large multinational – this time the focus on whether the Netherlands grated special tax treatment to an IKEA subsidiary. The Commission is investigating Dutch tax rulings . . .
Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy’s transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .
Daniel Garabedian and Steven Peeters of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss in detail the expected features of the Belgian government’s planned innovation income deduction regime, which would replace the patent income deduction regime . . .
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus have commenced . . .
As a part of its effort to address aggressive tax planning by large multinational groups, the UK government on May 12 launched a consultation on a proposal to introduce rules restricting interest . . .
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