Featured News

Denmark

Draft Danish bill would tighten transfer pricing rules

October 7, 2020

Susi Baerentzen, Ph.D., Copenhagen, discusses proposed changes to Denmark’s transfer pricing law, released for public consultation on October 4 . . .

Asia-Pacific

The EU’s latest list of non-cooperative tax jurisdictions

October 7, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses October 6 revisions to the EU Commission’s list of non-cooperative jurisdictions in taxation . . .

Belgium

The new Belgian government’s agreement: a symphony with tax notes

October 7, 2020

Geoffroy Galéa, Of Counsel and Head of the Tax Practice at Fieldfisher, Brussels, discusses a policy paper, agreed to September 30 by Belgium’s new government, the so-called “Vivaldi coalition,” which includes the coalition’s position on international tax matters . . .

OECD to provide update of global tax negotiation on Monday

October 7, 2020

The OECD today announced that it will provide an update of the status . . .

Africa

COVID-19 test producer Qiagen’s intercompany financing – the transfer pricing issues

October 6, 2020

Dr. Harold McClure, a New York City Economist, discusses an analysis by Vincent Kiezebrink and Jasper van Teeffelen which accuses biotech firm Qiagen of base erosion through the use of intercompany loans . . .

Africa

Australia to change to corporate tax residency test

October 6, 2020

The Australian government will propose to change the corporate residency test used to determine if a company incorporated offshore is liable for income tax in Australia, budget documents released today . . .

Africa

African tax administrators release model digital services tax legislation, say global tax deal unlikely this year

October 1, 2020

The African Tax Administration Forum (ATAF), comprised of tax administrations from 38 African countries, on September 30, published sample digital . . .

Europe

Dutch opposition party proposes controversial dividend exit tax

September 30, 2020

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper, Amsterdam, discuss a Dutch proposal to introduce an exit tax to the dividend withholding tax which, if enacted, would apply to Dutch resident companies undertaking cross-border reorganizations as of September 18 . . .

Denmark

Spain must recover illegal state aid for tax lease schemes

September 30, 2020

Susi Baerentzen, Ph.D., Copenhagen, Denmark, discusses the General Court of the European Union’s September 23 ruling in the Spanish tax leasing case, aka the Lico Leasing case, a long-running taxation state aid dispute that had been referred back from the European Court of Justice in 2018 . . .

Europe

EU to propose system for harmonized withholding tax relief

September 30, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a tax proposal included in the EU Commission’s September 24 Capital Markets Union Action Plan . . . .

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

Europe

The 2021 Dutch tax plan: key takeaways for multinational enterprises

September 28, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper, Amsterdam, discuss the Dutch government’s September 15 tax legislative proposals, focusing on the items most relevant to multinational enterprises . . .

Americas

Peru and Japan: the road to a double tax treaty

September 28, 2020

Franz Salazar Anccasi, Tax Advisory Manager at Edwards Peru, Lima, Peru, discusses the status of a tax treaty being negotiated by Japan and Peru . . .

Americas

OECD, Brazil tax officials provide update of transfer pricing alignment project

September 28, 2020

Francisco Lisboa Moreira a tax partner at Bocater Advogados, São Paulo, Brazil, discusses a recent conference where senior OECD and Brazil tax officials provided an update on efforts to align Brazil’s transfer pricing laws with global standards . . . .

Europe

EU Commission appeals Apple State aid ruling

September 25, 2020

The European Commission today announced that it has appealed the EU General Court’s ruling in the Apple State aid case to . . .

Americas

Panama introduces EMMA tax regime to attract multinational manufacturers

September 25, 2020

Laura Pinilla, an associate at BaseFirma Colombia, discusses new Panama tax incentives for multinationals signed into law on August 31 . . .

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

September 25, 2020

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Europe

Poland provides more details on plan to require large firms to publicize tax strategy

September 24, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses a September 16 bill published by the Polish government requiring large corporations to prepare and publish a report on the execution of their tax strategy each fiscal year . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

September 23, 2020

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

September 23, 2020

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available

September 23, 2020

The international tax community needs to again thank McGill Professor Allison Christians for getting ahold of leaked copies of the latest versions of the pillar one and pillar two digital tax . . .

Africa

EU may address public country-by-country reporting this year, German minister says

September 21, 2020

The EU may soon take up the issue of whether country-by-country reports detailing the tax affairs of large multinationals should be made public, German Federal Minister of Finance Olaf Scholz said today . . .

Africa

Customs valuation and intercompany royalties: the Curtis Balkan case

September 21, 2020

Economist Dr. Harold McClure, New York City, discusses transfer pricing issues associated with intercompany royalties . . .

Americas

The transfer pricing implications of Armani’s US advertising payments

September 17, 2020

New York City economist Dr. Harold McClure discusses a difficult transfer pricing issue often faced by multinational apparel and shoe manufacturers, namely, how to treat locally incurred advertising expenses where the foreign parent formally owns the trademarks . . .

Americas

US IRS again defers start date of foreign currency tax regulations

September 17, 2020

The US IRS has again deferred the applicability date of foreign currency . . .

Asia-Pacific

New Zealand provides Covid-19 transfer pricing guidance

September 16, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP, New Zealand, discuss recently released New Zealand Inland Revenue transfer pricing guidance for businesses affected by Covid-19 . . .

Europe

Poland proposal would require large companies to make their tax policies public

September 16, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses corporate taxation legislative changes proposed by Poland’s Minister of Finance on September 4 applicable to large corporations . . .

Americas

The protectionism of Biden’s cross-border tax plan

September 15, 2020

Daniel Bunn, Vice President of Global Projects at the Tax Foundation in Washington, analyzes US presidential candidate Joe Biden’s cross-border taxation proposals, made public last week, which aim to support his “Made in America” agenda . . .

Europe

First Look: Dutch Tax Plan 2021 released

September 15, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, note today’s release of Dutch Tax Plan 2021 and highlight some of the most important provisions for multinationals . . .

Europe

Sweden proposes to deny tax deductions for interest payments to companies located in EU blacklist countries

September 15, 2020

Madeleine Thörning, a transfer pricing specialist at Thorning Koponen Consulting in Stockholm, discusses the Swedish government’s September 3 proposal to deny tax deductions for interest payments made to companies located in countries listed on the European Union’s list of non-cooperative jurisdictions . . .

Americas

US publishes official version of interest expense deduction regs, changing them slightly from advance copy

September 14, 2020

The US IRS today published in the Federal Register final regulations that provide guidance on the business interest expense deduction limitation . . .

Europe

Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company

September 10, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a recent Italian Supreme Court decision addressing whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes where the court applied the European Court of Justice’s holdings in the so-called Danish cases . . .

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Europe

Poland clarifies treatment of dividends under transfer pricing rules

September 9, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses guidance issued August 6 by Poland’s Minister of Finance that addresses whether a dividend payment among associated companies falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. . . .

Americas

Chile’s new transfer pricing local file and master file obligations for multinationals

September 8, 2020

Francisco Sepúlveda of RGS Abogados, Santiago de Chile, discusses Chile transfer pricing guidance issued on August 31 . . .

Americas

Netherlands announces changes to tax treatment of Brazil interest on equity payments

September 7, 2020

Jian-Cheng Ku and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss August 27 Netherlands Ministry of Finance guidance describing the new Dutch policy with respect to the tax treatment of interest on equity payments under the Netherlands-Brazil tax treaty . . . .

Americas

Colombia publishes new guidance on the tax incentive for mega-investments

September 4, 2020

Cindy Simbaqueva, a transfer pricing manager at BaseFirma Colombia, Bogotá, discusses August 21 guidance published by the Colombian tax authority on Colombia’s mega-investment tax incentive . . .

Africa

Leaked OECD draft pillar one and pillar two digital tax blueprints available

September 3, 2020

McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints . . .

Americas

AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics

September 2, 2020

Dr. Harold McClure, a New York City economist, discusses key transfer pricing issues in the Tax Court of Canada’s August 27 ruling in AgraCity Ltd. v. the Queen, including issues involving co-distribution and the appropriate benchmarking for a logistics affiliate . . .

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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