Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
US House Republicans today presented their long-awaited tax reform bill, proposing to dramatically change the US international tax system.As expected, the Republican proposal includes a move to a territorial tax system accomplished by a foreign dividends received deduction. This is coupled with a deemed repatriation of existing earnings held offshore. The bill sets the deemed . . .
Mansi Seth and Joachim Saldanha of Nishith Desai Associates discuss an October 24 Indian tribunal decision which held that payments made by Google India to Google Ireland for marketing and distribution of online ad space through the Google’s AdWords program were royalty payments subject to withholding tax . . .
The European Commission has opened an in-depth State aid investigation into the UK’s controlled foreign company (CFC) tax laws applicable to multinationals, specifically, the CFC rules’ group financing exception. The group financing exception to the CFC rules, added in 2013, is applicable to multinationals . . .
The OECD on October 25 released public comments from 52 individuals and groups on the design of new international tax rules for digital firms. The comments aim to help an OECD task force prepare an interim report on the issue, to be presented to G20 finance ministers in April 2018. It is widely acknowledged that the current . .
Davide Anghileri of the University of Lausanne, an MNE Tax contributing editor, discusses a meeting of the UN Committee of Experts on International Cooperation in Tax Matters, held in Geneva 17– 20 October, where new committee co-chairs were elected and subcommittee assignments were set, including assignments for a new subcommittee on the digitization of the economy . . .
Twenty countries have tax laws considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .
Jim Stewart, an Adjunct Professor in Finance at Trinity Business School, Trinity College, Dublin, writes that Irish budget 2018, released today, proposes to limit deductions for intellectual property expenditures, but contains few other changes directly affecting the Irish corporate tax regime . . .
As expected, the ECOFIN Council today approved a directive establishing a new system for resolving double taxation disputes between EU member states. The new directive on tax dispute resolution follows an agreement reached by EU nations on May 23. It was approved without discussion. Member states will have until June . . .
Jitendra Jain, Executive Director at PricewaterhouseCoopers, India, discusses India’s much-awaited rules on the implementation of the master file and country-by-country report, released yesterday, focusing on the differences between India’s master file requirement and the OECD’s prescribed format and recommending next-steps to comply with the requirements . . .