Americas
Europe
Africa
Ireland says tax treaty with Ethiopia entered into force, updates status of treaties with Ghana, Oman, South Africa
Irish Revenue has announced that a new double taxation agreement with Ethiopia entered into force on August 12. The treaty, signed November 3, 2014, will . . .
Europe
Europe
Asia-Pacific
Japan and Belgium agree to terms of new tax treaty
Japan and Belgium have agreed to the terms of new tax treaty, Japan’s Ministry of Finance announced . . .
Europe
Europe
EU finance ministers wary of anti-tax avoidance proposal
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for . . .
Europe
EU Commission staff analyzes financial transaction tax→
The paper, Financial Transaction Taxes in the European Union, was written by Thomas Hemmelgarn, Gaëtan Nicodème, Bogdan Tasnadi, and Pol Vermote. See: EU Commission.
Europe
Europe
UK Treasury minister defends Google tax settlement
UK Treasury Secretary David Gauke today defended an HM Revenue and Customs settlement with Google relating to back taxes, telling Members of Parliament that the company . . .
Europe
Luxembourg law adapting corporate tax code to EU law contains gaps
Paloma Schwarz Martínez, a PhD Researcher at the University of Luxembourg, analyzes Luxembourg’s new law implementing changes made to the EU Parent-Subsidiary directive, noting that restrictions on hybrid mismatch arrangements and new antiabuse rules will not apply when non-EU companies are involved in a transaction.
Europe
Asia-Pacific
Europe
Europe
Denmark
Europe
Europe
Europe
Estonia
Europe
Europe
Why France’s appellate court concluded that ValueClick’s French subsidiary did not have a PE in France
Terence Wilhelm, managing partner of CARA Avocats, Lyon area, France, discusses key takeaways from the Paris Administrative Appeal Court’s recent decision in ValueClick, where the court adopted a restrictive view of the concept of permanent establishment applying the applicable French tax treaty based on the old OECD model . . .
Europe
OECD model tax treaty shouldn’t guide EU law on beneficial ownership, Advocate General says
The EU Advocate General of the Court of Justice of the European Union, Juliane Kokott, on March 1, released her opinion in four cases dealing with the interpretation of the beneficial ownership concept where the Interest Royalty Directive applies and in two cases where the Parent-Subsidiary Directive applies, writes Davide Anghileri of the University of Lausanne . . .
Europe
Europe
Europe
Americas
Americas
Europe
Europe
Americas
Europe
France’s additional tax on dividends is contrary to law, EU court concludes
The European Court of Justice in May 17 decision ruled that France’s additional tax on dividends is not compatible with article 4 of the parent-subsidiary directive, writes Davide Anghileri of the University of Lausanne . . .
Europe
Europe
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
Europe
France’s denial of dividend withholding tax exemption under EU scrutiny
The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri of the University of Lausanne . . .
Europe
EU Commission releases opening decision in State aid probe of Luxembourg tax rulings granted Engie
The European Commission today published a non-confidential version of its decision to open a State aid investigation into whether a tax rulings granted by Luxembourg to Engie, formally known as GDF Suez . . .
Americas
Starbucks files suit challenging Commission’s decision on State aid in tax case
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission’s decision of October 21, 2015, which concluded that an advance pricing agreement . . .
Americas
Switzerland agrees to automatic exchange of information with Brazil, Mexico, Uruguay
Davide Anghileri of the University of Lausanne discusses Switzerland’s November 18 signing of joint declarations on the introduction of automatic exchange of information in tax matters with Brazil, Mexico, and Uruguay
. . .
Europe
Argentina, Switzerland agree to automatically exchange financial account information for tax purposes
Davide Anghileri of the University of Lausanne discusses the November 16 signing by Switzerland and Argentina of a joint declaration on the introduction of automatic exchange of information in tax matters . . .
