Europe
Europe
Europe
Europe
Europe
Europe
Italian Supreme Court rejects Luxembourg company tax appeal, finds parent-subsidiary directive inapplicable
Gian Luca Nieddu of Hager & Partners, Milan area, discusses a recent Italian Supreme Court decision rejecting an Italian corporation’s request for reimbursement of withholding taxes paid on dividends distributed to its Luxembourg parent; the author argues that the opinion is based on faulty reasoning . . .
Americas
Digital Economy
Denmark
Americas
Europe
Europe
Europe
Europe
Europe
Europe
Europe
Court voids French law denying withholding tax exemption for dividends paid outside EU
Davide Anghileri of the University of Lausanne discusses an EU Court of Justice ruling, delivered September 7, which concludes that France violated EU law when it applied a general antiabuse rule to deny a withholding tax exemption for dividends distributed by a resident subsidiary to a company controlled by a resident of a non-EU State . . .
Europe
Asia-Pacific
Feedback sought in review of 8 countries’ tax dispute resolution processes
The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .
Asia-Pacific
Japan to sign tax treaties with Denmark and Estonia
Japan’s Ministry of Finance today announced that it has reached agreements in principle for tax treaties . . .
Europe
Italy: Google to pay 306 million euros to settle tax dispute
Google has settled a tax dispute in Italy, writes Davide Anghileri of the University of Lausanne . . .
Europe
Belgium
Europe
UK draft tax legislation would modify carried-forward loss rules, limit interest deductions
Julian Feiner of Dentons, London, discusses draft UK proposals, released yesterday, that would change the taxation of carried-forward losses and interest deductions . . .
Europe
Europe
EU Commission to draft financial transaction tax legislation
The EU Commission has been asked to prepare draft legislation for a financial transaction tax (FTT) following significant progress made on the design of the tax . . .
Asia-Pacific
Japan, Belgium sign tax treaty
Japan and Belgium today signed a new tax treaty, Japan’s Ministry of Finance . . .
Americas
Americas
US criticizes EU probe of multinational corp tax as Apple decision nears
The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .
Europe
Ireland’s tax authority issues FAQs on country-by-country reporting
Irish Revenue on June 23 issued a set of frequently asked questions regarding new Irish tax legislation and regulations that require country-by-country reporting by . . .
Europe
Finland and Portugal agree to terms of new tax treaty
Finland’s Ministry of Finance today announced that it has reached an agreement with the Portuguese government on the terms of a . . .
Europe
UK’s HMRC details new requirement for large businesses to publish tax strategy
The UK’s HM Revenue and Customs (HMRC) on March 31 published draft guidance describing new rules that will require large companies, partnerships . . .
Europe
Dutch court clarifies dividend withholding tax refund for foreign shareholders
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze Dutch Supreme Court decisions issued March 4 in Miljoen, X, and Société Général, concerning the calculation of dividend withholding tax refunds due portfolio investors . . .
Europe
Europe
Americas
Czech Republic
Europe
Asia-Pacific
Europe
German tax law permitting loss carryforward following restructuring of failing companies is not State aid, EU court rules
Konstantin Sakuth of Linklaters LLP, Munich, discusses a June 28 European Court of Justice decision which settled a long-running debate regarding the legality under EU State aid rules of Germany’s “restructuring clause,” which allows carryback of tax losses following some company restructurings . . .
