The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
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, . . .
The Dutch Supreme Court has asked the Court of Justice of the European Union to resolve two separate disputes concerning whether the Netherlands can deny foreign investment funds refunds of the Dutch dividend withholding . . .
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .