Asia-Pacific
Portugal ratifies tax treaty with Georgia
Portugal, on March 5, ratified at tax treaty Georgia, signed December 12, 2012. An English-language version of the treaty is available
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Europe
Europe
Tax officials at BEPS hearing reject business reps’ interest deduction proposal
Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .
Europe
Ireland issues guidance on foreign tax credit for foreign dividends
The Irish government on January 29 released guidance clarifying a law added in the Finance Act 2013 that provides for an additional foreign tax credit for foreign dividends received . . .
Europe
EU says Luxembourg APA does not price Amazon intra-group royalties at arm’s length, likely violating state aid
An advance pricing agreement (APA) issued to Amazon by the Luxembourg tax authorities setting the price of intra-group royalties seems to be designed to ensure a predictable level of profit to Amazon’s Luxembourg operations rather than to achieve an arm’s length result, and thus appears likely to be state aid, the European Commission . . .
Africa
Europe
Crimea residents receive new tax breaks
Russian President Vladimir Putin on December 1 signed addendums to the country’s tax code providing enhanced tax benefits to residents of the free economic zone in Crimea, Russian news agency TASS has reported. Under the new provisions . . .
Europe
Jersey and Romania sign TIEA
Jersey and Romania on December 1 signed a tax information exchange agreement (TIEA) at the Romanian Embassy in London, the government of Jersey has . . .
Asia-Pacific
Spanish law permitting tax amortization of financial goodwill for indirect shareholdings violates state aid, says Commission
The European Commission has concluded that a Spanish tax scheme benefiting companies that acquire foreign shareholdings is incompatible with EU state aid rules . . .
Europe
Ireland to close “double Irish,” but not until 2020 for existing arrangements
Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.
Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
Czech Republic
Tax treaty between Luxembourg and Czech Republic enters into force
The requirements for the entry into force of the treaty between Luxembourg and the Czech Republic, signed March 5, 2013, were met on July 31 and the treaty entered into force as of that date, the Luxembourg tax authority has announced. Release (in French), A Memorial – No. 162 of August 14, page A 2501 (in French)
Albania
Albania releases guidance on new transfer pricing regime
Albania’s Ministry of Finance has issued guidance on new Albanian transfer pricing laws which became effective in June, according to a July 25 report by EY. For a detailed discussion of the new guidance, see EY.
Europe
Ireland launches its own BEPS consultation
Ireland’s Department of Finance, on May 27, announced a consultation to consider international stakeholder’s views on how Ireland’s tax system should respond to the OECD’s base erosion and profit shifting (BEPS) initiative.
“Ireland remains 100% committed to the 12.5% corporation tax rate.
See also, Why Ireland should address corporate tax residency rules before we’re forced to, By Feargal O’Rourke, The Irish Times
