Europe

Company may deduct VAT paid on consultancy fees for failed takeover, EU Advocate General concludes

May 9, 2018

Davide Anghileri, University of Lausanne discusses an opinion of Advocate General Kokott of the European Court of Justice concluding that VAT paid on consultancy fees and other expenditures related to a takeover can be recovered even though the takeover bid failed . . .

Asia-Pacific

UK proposes to change to BEPS MLI reservations and notifications

April 16, 2018

The UK government today announced proposed changes to the provisional reservations and notifications it made when it signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent . . .

Asia-Pacific

OECD publishes reports covering cross-border tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

March 13, 2018

The OECD today published reports approved by the “Inclusive Framework on BEPS” which assess tax dispute resolution practices in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. As members . . .

Americas

Ireland, Bahamas tax information exchange agreement enters into effect

February 7, 2018

A tax information exchange agreement between Ireland and the Bahamas has entered into effect, Irish Revenue announced February 7. The agreement, signed January 12, 2015, allows for the exchange of information . . .

Asia-Pacific

Ireland, Kazakhstan tax treaty enters into force

January 12, 2018

Irish Tax and Customs on January 12 announced that attax treaty between Ireland and Kazakhstan entered into force on December . . .

Europe

Irish Budget 2018 makes makes only minor changes to corporate taxes

October 10, 2017

Jim Stewart, an Adjunct Professor in Finance at Trinity Business School, Trinity College, Dublin, writes that Irish budget 2018, released today, proposes to limit deductions for intellectual property expenditures, but contains few other changes directly affecting the Irish corporate tax regime . . .

EU nations’ split over tax revealed at digital summit: EURACTIV.com→

October 2, 2017

Europe

Norway may deny deduction for group contribution to foreign related company, EFTA court rules

September 18, 2017

The European Free Trade Association (EFTA) Court has clarified when an EFTA State (at present, Iceland, Liechtenstein, Norway and Switzerland) may deny a tax deduction for an intragroup contribution to a foreign company, writes Davide Anghileri . . .

Switzerland: Tax Proposal 17 consultation initiated

September 7, 2017

Switzerland’s Federal Council on September 6 initiated a consultation on a new proposal to reform the Swiss corporate tax system, known as Tax Proposal 17, writes Davide Anghileri of the University of Lausanne . . .

Europe

Swedish tax plan would cut corporate rate, limit deduction for interest, hybrids: EY→

June 21, 2017

EU prepares challenge to Trump border tax plan: The Telegraph→

February 15, 2017

See: The Telegraph.

Africa

Ireland initials tax treaty with Oman, treaties with Botswana, Ethiopia enter into effect

February 7, 2017

Ireland has concluded negotiations for a new tax treaty with Oman and expects the treaty to be signed shortly, Irish Revenue . . .

Asia-Pacific

India-Cyprus tax treaty renegotiated: key provisions

December 12, 2016

Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm’s international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .

Europe

New European VAT rules for cross-border e-commerce proposed

December 8, 2016

Davide Anghileri of the University of Lausanne discusses the European Commission’s December 1 proposal to modernize and unify throughout Europe the value added tax (VAT) rules for cross-border business-to-consumer (B2C) e-commerce . . .

Europe

OECD finalizing BEPS multilateral instrument, concerned about EU state aid tax probes

September 22, 2016

Officials are putting the finishing touches on the multilateral instrument (MLI) to implement the OECD/G20 base erosion profit shifting (BEPS) measures, keeping it on track to be finalized this fall, senior . . .

European finance ministers adopt anti-tax avoidance directive

July 12, 2016

The EU Economic and Financial Affairs Council (ECOFIN) today formally adopted without discussion the Anti-Tax Avoidance Directive (ATAD), designed to tackle multinational corporation tax . . .

Europe

Netherlands considers corporate rate cut: Janene Pieters / NL Times→

June 24, 2016

See: NL Times

EU moving forward with tax haven blacklist: Francesco Guarascio / Reuters→

May 19, 2016

See: Reuters

Europe

Trial of “Lux Leaks” whistleblowers, journalist to begin in Luxembourg: Michele Sinner and Robert-Jan Bartunek / Reuters→

April 25, 2016

See: Reuters. More: France 24, The Guardian.

Americas

US IRS Appeals rules Delphi not liable for US tax on worldwide profits under inversion rules: Dustin Walsh / Crain’s Detroit Business→

April 14, 2016

See: Crain’s Detroit Business. More: SEC Form 8K (Streetinsider.com), Reuters, Wall Street Journal.

EU Commission expected to advance proposal allowing member states more freedom to set VAT rates: Ruth Berschens / Handelsblatt→

March 30, 2016

See: Handelsblatt. More: Financial Times.

Europe

EU expected to propose public country-by-country reporting of multinationals’ tax information

February 8, 2016

The European Commission will likely propose EU-wide legislation requiring large multinationals to publicly report their European profits and . . .

Belgium

Belgium may withdraw from EU financial transactions tax talks: Rebecca Christie / Bloomberg→

January 25, 2016

See: Bloomberg. More: Europe Online Magazine, The Brussels Times.

Europe

France’s digital tax may not comply with EU law on freedom of establishment, free competition: Out-Law→

March 14, 2019

Africa

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

January 31, 2019

The OECD has published a progress report detailing whether countries are meeting their commitments to . . .

Europe

Professors discuss German proposal for an internationally coordinated minimum tax on MNE profits: Johannes Becker & Joachim Englisch / Tax Justice Network→

January 16, 2019

Digital Economy

France to introduce “GAFA tax” on large internet and technology companies from January 1, giving up on EU digital tax deal: DW.com→

December 18, 2018

In early December, Economy Minister Bruno Le Maire said . . .

More: BBC News.

Digital Economy

Not everyone’s cup of DST: five thoughts on the UK digital services tax consultation

November 15, 2018

Julian Feiner of Dentons, London, discusses the UK’s November 8 consultation on a proposed new digital services tax, identifying key takeaways from the paper . . .

EU ministers agree to VAT fixes, new rules for electronic publications

October 2, 2018

EU finance ministers at their meeting today in Luxembourg agreed to fix several . . .

Asia-Pacific

Nepal committee formed to study signing tax treaty with UK, other nations: My Republica→

September 24, 2018

Belarus

UK-Belarus tax treaty enters into force

August 10, 2018

The UK-Belarus tax treaty, signed September 26, 2017, entered into force on July 27, the UK government . . .

Americas

US imposes tariffs on EU, Canada, Mexico of 25 percent on imported steel, 10 percent on imported aluminum: Jeremy Diamond & Julia Horowitz / CNN Money→

May 31, 2018

Americas

Brazil signs key tax agreements with Singapore and Switzerland

May 23, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo, and Matheus de Moura Sena, of KPMG, Singapore, analyze new tax treaties signed by Brazil earlier this month with Singapore and Switzerland . . .

Switzerland shares private tax rulings with other nations for the first time

May 10, 2018

Switzerland’s Federal Tax Administration (FTA) on May 8 announced that for the first time it transmitted information on private tax rulings to partner states thus meeting its obligation of spontaneous exchange of information, writes Davide Anghileri, University of Lausanne . . .

EU Commission, by focusing on the low effective corporate tax rates of the largest digital firms, incorrectly concludes that digital firms pay too little tax, think tank concludes: Matthias Bauer / ECIPE→

March 20, 2018

Europe

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

Europe

Company may deduct VAT paid on consultancy fees for failed takeover, EU Advocate General concludes

UK proposes to change to BEPS MLI reservations and notifications

OECD publishes reports covering cross-border tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

Ireland, Bahamas tax information exchange agreement enters into effect

Ireland, Kazakhstan tax treaty enters into force

Irish Budget 2018 makes makes only minor changes to corporate taxes

EU nations’ split over tax revealed at digital summit: EURACTIV.com→

Norway may deny deduction for group contribution to foreign related company, EFTA court rules

Switzerland: Tax Proposal 17 consultation initiated

Swedish tax plan would cut corporate rate, limit deduction for interest, hybrids: EY→

EU prepares challenge to Trump border tax plan: The Telegraph→

Ireland initials tax treaty with Oman, treaties with Botswana, Ethiopia enter into effect

India-Cyprus tax treaty renegotiated: key provisions

New European VAT rules for cross-border e-commerce proposed

OECD finalizing BEPS multilateral instrument, concerned about EU state aid tax probes

European finance ministers adopt anti-tax avoidance directive

Netherlands considers corporate rate cut: Janene Pieters / NL Times→

EU moving forward with tax haven blacklist: Francesco Guarascio / Reuters→

Trial of “Lux Leaks” whistleblowers, journalist to begin in Luxembourg: Michele Sinner and Robert-Jan Bartunek / Reuters→

US IRS Appeals rules Delphi not liable for US tax on worldwide profits under inversion rules: Dustin Walsh / Crain’s Detroit Business→

EU Commission expected to advance proposal allowing member states more freedom to set VAT rates: Ruth Berschens / Handelsblatt→

EU expected to propose public country-by-country reporting of multinationals’ tax information

Belgium may withdraw from EU financial transactions tax talks: Rebecca Christie / Bloomberg→

France’s digital tax may not comply with EU law on freedom of establishment, free competition: Out-Law→

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

Professors discuss German proposal for an internationally coordinated minimum tax on MNE profits: Johannes Becker & Joachim Englisch / Tax Justice Network→

France to introduce “GAFA tax” on large internet and technology companies from January 1, giving up on EU digital tax deal: DW.com→

Not everyone’s cup of DST: five thoughts on the UK digital services tax consultation

EU ministers agree to VAT fixes, new rules for electronic publications

Nepal committee formed to study signing tax treaty with UK, other nations: My Republica→

UK-Belarus tax treaty enters into force

US imposes tariffs on EU, Canada, Mexico of 25 percent on imported steel, 10 percent on imported aluminum: Jeremy Diamond & Julia Horowitz / CNN Money→

Brazil signs key tax agreements with Singapore and Switzerland

Switzerland shares private tax rulings with other nations for the first time

EU Commission, by focusing on the low effective corporate tax rates of the largest digital firms, incorrectly concludes that digital firms pay too little tax, think tank concludes: Matthias Bauer / ECIPE→

Ukraine says 13 more countries subject to control under transfer pricing law: Interfax-Ukraine→

Isle of Man, Turkey tax information exchange pact to enter into force

Analysis of EU Commission digital transaction communication: Diane Ring / Surly Subgroup→

EU tax agenda includes VAT modernization for digital economy, intermediaries crack-down