Europe

Gibraltar announces increase in corporate tax rate from 10% to 12.5% to ease transition to anticipated 15% rate under proposed global minimum tax agreement: Gibraltar Chief Minister’s Budget Address 2021→

July 20, 2021

Ireland

Global minimum tax negotiations could land at ‘a bit higher’ rate than 15%, OECD tax director Pascal Saint-Amans says, adding that agreement will proceed with or without Ireland: Irish Times→

July 19, 2021

Americas

Nike’s transfer pricing state aid dispute: the underlying issues

July 19, 2021

New York City Economist Dr. J. Harold McClure analyzes the issues underlying the transfer pricing dispute involving Nike, following the General Court of the European Union’s July 14 ruling declining to annul the European Commission’s state aid investigation regarding . . .

Denmark

Denmark finally implements ATAD amendments to CFC regime

July 19, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish parliament’s June 3 passage of a bill to adopt changes to the controlled foreign corporation (CFC) regime necessary for the implementation of the EU Anti-Tax Avoidance Directive (ATAD) . . .

Asia-Pacific

Japan and Switzerland sign tax treaty protocol

July 16, 2021

Japan and Switzerland on July 16 signed an amending protocol to the tax treaty between the countries that would revise the treatment of taxes on investment income, among . . .

Accounting

European accounting group advises on deferred tax changes, seeks comments

July 15, 2021

The European Financial Reporting Advisory Group (EFRAG) on July 14 issued a draft letter to the European Commission recommending endorsing the amendments to international accounting standard (IAS) 12 regarding . . .

Europe

Ireland will likely give up its 12.5% corporate tax rate later this year in response to OECD tax agreement impetus, Irish government officials reportedly suggest: Daniel McConnell / Irish Examiner→

July 15, 2021

Europe

EU court rejects Nike’s challenge of transfer pricing state aid investigation

July 14, 2021

The General Court of the EU on July 14 dismissed an action by Nike to annul a decision by the European Commission to investigate whether advance pricing agreements (APAs) concluded by the Netherlands with Nike constituted . . .

Carbon Tax

EU ‘Green Deal’ includes energy tax changes, carbon border adjustment mechanism

July 14, 2021

The European Commission on July 14 adopted its “Green Deal” package of proposals to address climate change through various policy measures, including revisions to the tax system applicable to energy products and a new . . .

Europe

Poland proposes changes to transfer pricing regulations

July 13, 2021

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s June 28 launch of taxpayer-friendly amendments to its transfer pricing regulations, including changes to regulations introduced in 2019 that . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Belgium

Belgium proposes tax bill on foreign loss deductions

July 12, 2021

Moïse Gnakouri, Catholic University of Louvain, discusses the Belgian government’s May 27 draft bill that would change the income tax code regarding the conditions for deducting losses realized by . . .

Europe

Luxembourg government contests press reports about tax authorities accepting as binding informal tax rulings authored by taxpayers or their advisors: Luxembourg Ministry of Finance→

July 9, 2021

Europe

EU digital levy to be proposed July 20 will consist of 0.3% tax on goods and services sold online by companies in EU with turnover of at least EUR 50 million (USD 59 million): Bjarke Smith-Meyer / Politico→

July 8, 2021

Asia-Pacific

UK-based Cairn Energy garners court order in France to seize Indian government property valued at more than EUR 20 million in enforcement of international arbitration award: Tribune India→

July 8, 2021

Accounting

Ireland consults on tax rules relating to interest limitation, hybrids

July 7, 2021

On July 2, the Irish Department of Finance opened for comment tax statements on the anti-reverse hybrid rule and interest limitation ratio rule, which will transpose requirements of the . . .

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Europe

Italian revenue agency’s new tax assessment guidelines affect multinationals

July 6, 2021

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss the Italian revenue agency’s May 7 guidelines describing its plans to prevent and fight tax evasion, along with an indication of how it will . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Thank you to our MNE Tax founder and community as we grow our platform

July 1, 2021

We are launching an exciting new chapter at MNE Tax, expanding our content and community of expert contributors in collaboration with our new parent CrossBorder Solutions. We would not have gotten to this point without . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Europe

Italian tax authorities accuse Booking.com of VAT fraud

June 30, 2021

Daniele Majorana, MICCINESI Tax, discusses the Italian finance police’s June 10 announcement of an investigation into whether online travel agency Booking.com evaded payment of around EUR 153 million (USD 182 million) in value-added tax (VAT) . . .

Europe

EU’s new VAT rules on online shopping enter into force July 1, affecting online sellers and platforms located both in and outside the EU: European Commission→

June 29, 2021

Europe

Dutch report on international tax and transfer pricing rulings reflects new ruling practice

June 29, 2021

Clive Jie-A-Joen and Monique van Herksen, Simmons & Simmons LLP, analyze the June 15 Dutch Revenue Service’s 2020 annual report on international tax rulings, focusing particularly on the advance pricing agreements that . . .

Europe

Spain amends MAP rules for tax and transfer pricing disputes

June 29, 2021

Mario Ortega Calle and Íñigo García Fernández, J&A Garrigues, S.L.P., discuss Spain’s June 8 approval of Royal Decree 399/2021, improving its mutual agreement procedure (MAP) for resolving double taxation . . .

Europe

European tax study confirms slow downward trend in corporate tax rates in EU, with both average top and effective corporate tax rates falling 1.5 percentage points over last decade to 21.4% and 19.2%, respectively: European Commission→

June 28, 2021

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

MNE Tax joins CrossBorder Solutions!

June 23, 2021

MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Europe

Russian tax authorities clarify application of domestic general anti-avoidance rules

June 23, 2021

Alexey Ryabov, JTI Russia, discusses Russian tax guidance issued on March 11 establishing criteria for applying the general anti-avoidance rule under Article 54.1 of the tax code aimed at . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Europe

EU consults on plan to tackle debt-equity bias in corporate taxation through measures aimed at equalizing tax treatment of debt and equity to be combined with accompanying anti-abuse provisions: European Commission→

June 22, 2021

Accounting

Finnish court accepts US GAAP as basis for transfer pricing in landmark ruling

June 22, 2021

Heikki Vesikansa, Jenni Parviainen, and Stefan Stellato, Hannes Snellman Attorneys Ltd., discuss a key June 2 Finnish Supreme Administrative Court ruling (SAC 2021:73), confirming the acceptability of a foreign . . .

Ireland

Ireland will seek yet-to-be-defined compromise in global minimum tax talks with aim of preserving room for tax competition by smaller countries, Irish Finance Minster says: Silvia Amaro / CNBC→

June 21, 2021

Europe

EU customs regulations will require payment of import turnover tax on goods valued under EUR 22 starting July 1: Austrian Ministry of Finance→

June 18, 2021

Europe

Finland court rejects tax authority’s transfer pricing approach to intercompany interest rates

June 17, 2021

New York City Economist Dr. Harold McClure discusses a May 21 Finnish Supreme Administrative Court decision which rejected the Finnish tax authority’s attempt to increase the intercompany interest rates charged by a Finnish financing affiliate to its Russian operating affiliate . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Europe

Royalty payments from Ireland to US jumped from about EUR 8 billion (USD 9.6 billion) annually to EUR 52 billion (USD 62.5 billion) in 2020, concludes report published on Irish government website: Seamus Coffey / University College Cork→

June 16, 2021

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

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