Europe
Italy’s Supreme Court rules French holding company has sufficient substance for tax purposes
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Switzerland weighs expansion of automatic exchange of tax information to 20 more countries
Davide Anghileri of the University of Lausanne discusses Switzerland’s decision to launch a consultation on automatic exchange of information with 20 more countries . . .
Japan and Lavia sign first tax treaty, text available
The governments of Japan and Latvia today signed a their first tax treaty, Japan’s Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .
Japan, Lithuania initial draft tax treaty
Japan and Lithuania have agreed in principle to a tax treaty, Japan’s Ministry of Finance . . .
Swiss tax treaty protocols with Norway, Albania enter into force
Switzerland’s Federal Council has today announced that tax treaty protocols with Albania and Norway. . .
France: public county-by-country reporting declared unconstitutional
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
UK releases draft legislation to limit interest deductions of large corporations
The UK government, on December 5, published draft clauses for a tax law that will limit the interest deductions of large corporations, to be included in the 2017 . . .
Draft German tax law adopts low threshold for transfer pricing master file, combats MNE tax avoidance
Tax specialist, Ninja-Antonia Reggelin, discusses a proposed new German tax law to combat multinational profit shifting, which includes implementation of transfer pricing documentation and country-by-country reporting and exchange of tax rulings, as well as several other measures. . .
Netherlands proposes modified innovation box tax regime
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, discuss a new proposal to revise the Dutch innovation box regime, which provides a reduced tax rate for profits derived from intangibles . . .
EU Commission lays out vision for new European VAT system
The EU Commission on April 7 presented its VAT action plan, designed to update the EU VAT system to make it more fraud-proof, reduce administrative burdens, account for the digital . . .
EU seeks to improve cross-border business tax dispute resolution
The European Commission on February 16 launched a public consultation seeking feedback on ways to improve the resolution of double . . .
Hong Kong, Russia tax treaty signed
Hong Kong and Russia signed a new tax treaty on January 19, Hong Kong’s Inland Revenue Department . . .
EU updates list of non-cooperative jurisdictions in taxation matters
Today the Council of the European Union removed Barbados, Grenada, the Republic of Korea, Macao SAR, Mongolia, Panama, Tunisia and the United Arab Emirates from the EU list of non-cooperative jurisdictions in taxation matters, writes Davide Anghileri of the University of Lausanne, Switzerland . . . .
Isle of Man ratifies multilateral treaty aimed at tax avoidance
The Isle of Man has become the second nation to ratify a multilateral tax treaty designed to prevent tax avoidance by multinational firms. The Isle of Man follows Austria, depositing its instrument of ratification of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD