Austria
Spain
Europe
Europe
Digital Economy
Americas
Africa
Europe
Europe
Americas
Europe
Asia-Pacific
Feedback sought in review of 8 countries’ tax dispute resolution processes
The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .
Asia-Pacific
Africa
Austria
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Africa
Europe
Africa
Americas
Tax officials crafting plan to jointly identify large multinationals with low risk of tax avoidance
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Austria
Europe
Denmark
Europe
Europe
ECJ rules in Spanish goodwill cases, implications for Apple, Fiat, Starbucks State aid cases
Dimitrios Kyriazis, a Doctoral Researcher in Law at the University of Oxford, analyzes the European Court of Justice’s judgment in the so-called Spanish goodwill cases, released December 21, and addresses the ruling’s impact on the Apple, Fiat, Starbucks State aid cases . . .
Belgium
EU Commission to investigate tax ruling practices of all EU states
The European Commission has enlarged its state aid investigation into private tax ruling practices to cover all 28 European Union states. “The Commission will ask Member States to provide information about their tax ruling practice, in particular to confirm whether they provide tax rulings, and, if they do, to request a list of all companies that have received a tax ruling from 2010 to 2013,” the Commission said December 17 in a press release . . .
Americas
Spain and Canada sign protocol to tax treaty
Spain and Canada have signed a protocol their update their tax treaty, the Spanish government announced on November 18. The new protocol would update . . .
Europe
Amazon stops routing some European profits through low-tax Luxembourg
Amazon has confirmed that as of May 1 it began booking profits from sales in the UK, Italy, Spain, and Germany in the country where the sale actually took place rather than in low-tax Luxembourg. See, New York Times, Wall Street Journal, Financial Times, The Independent, International Business Times, The Guardian, Tim Scott – Tax is an Accrual Business, Out-Law.com
Europe
Spanish government publishes draft regs requiring country-by-country reporting for MNEs
The Spanish government has published draft regulations, effective January 1, 2016, that require country-by-country reporting for multinationals consistent with guidance released under the OECD/G20 base erosion and profit shifting plan, writes PwC in an April 9 tax alert. For details, see PWC.
Europe
Spanish government to require country-by-country reporting for MNEs
The Spanish government on January 20 announced that it will issue regulations, expected to become effective January 1, 2016, that will require country-by-country reporting for multinationals, writes EY in a January 23 Global Tax Alert. For details, see EY.
Europe
Spain adopts new transfer pricing documentation rules including country-by-country reporting – PWC
In addition to the new documentation rules, the new Spanish law, enacted July 11, revises transfer pricing comparability analysis standards, provides for repatriation following a transfer pricing adjustment, and offers a special advance pricing agreement procedure for Spain’s patent box regime, writes PWC in an August 3 alert. See: PWC. More: EY.
Americas
US Senate Foreign Relations Committee approves eight long-pending tax treaties, Rand Paul not present for the vote
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual administrative assistance treaty. . .
Americas
US Treasury official urges Senate committee to approve ratification of pending tax treaties
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
Europe
Spain enacts corporate tax reform
Spain has enacted major tax reform, including corporate tax reform, effective January 1, 2015, writes Deloitte in a December 2 alert. The corporate tax changes include a reduction in tax rates for 2015 and 2016, anti-hybrid rules and . . .
Europe
Spain, Guernsey sign tax information exchange agreement
Guernsey and Spain on November 10 signed an agreement on exchange of information . . .
Europe
Europe
EU Commission to take Spain to court over tax scheme for foreign dividends
The European Commission will challenge Spanish laws governing the taxation of dividends distributed by a non-resident companies to Spanish companies in the European Court of Justice, the Commission announced November 26. The Commission said that Spain . . .
Europe
France and Spain agree to improve exchange of tax information
French Finance Minister Michel Sapin and Swiss Finance Minister Eveline Widmer-Schlumpf, on June . . .
Europe
UK, France, Germany, Italy and Spain agree on automatic exchange of information
Finance ministers from the UK, France, Germany, Italy and Spain, on 28 April, agreed to sign new global standards of automatic exchange of tax information at the October Global Forum meeting in Berlin. The countries will begin to automatically exchange information in 2017, with respect to data collected from 31 December 31, 2015. UK Press Release, German Press Release, French Press Release
Europe
UK changes guidance on Dutch and Spanish VAT grouping rules under the ECJ’s Skandia ruling
The UK’s HMRC, in Customs Brief 23 issued December 11, updated its view of how UK businesses must account for VAT on intragroup supplies of services to branches that are part of VAT groups located in the Netherlands or Spain, following the European Court of Justice’s ruling in Skandia America . . .
