Featured News

Europe

EU Member State COVID-19 relief should not benefit tax havens, Commission says

July 15, 2020

Francesca Amaddeo a Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the EU Commission’s July 14 recommendation that European states not tie COVID-19 tax relief measures with tax havens . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .

Europe

EU Commission releases decision extending scope of State aid investigation into IKEA’s Dutch taxation

July 14, 2020

The European Commission on July 19 released a copy of its decision to widen the scope of its in-depth investigation into the Netherlands’ tax treatment of an IKEA subsidiary . . .

Americas

Canada Appeals Court rules in Cameco’s transfer pricing dispute involving Swiss subsidiary

July 14, 2020

Warren Novis, Head of Transfer Pricing at BDO, Ireland, discusses the Canada Federal Court of Appeal’s decision in Cameco, a long-standing transfer pricing dispute . . .

Americas

First Look: IRS finalizes guidance on deduction for foreign-derived intangible income and global intangible low-taxed income

July 9, 2020

The US IRS today issued final regulations that provide guidance for corporations on the deduction . . .

Europe

EU General Court decisions on Ireland v Commission, Apple v Commission expected next week

July 9, 2020

The EU General Court will release its decisions in the Apple state aid cases — Ireland v Commission and Apple Sales International . . .

Africa

New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior

July 8, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark discusses the OECD’s July 9 release of data on 4,000+ MNE groups . . .

Africa

UN committee to draft model tax treaty provisions addressing digital economy, transfer pricing manual updates approved

July 8, 2020

The UN Committee of Experts on International Cooperation in Tax Matters, at its 20th session, agreed to consider adding new provisions addressing the taxation of the digital economy to the UN Model Double Taxation Convention between Developed and Developing Countries, UN officials . . .

Asia-Pacific

New Saudi Arabia tax guidance addresses mutual agreement procedure

July 8, 2020

Asmae Bazaani and Mohammed Abu-Hijleh of Deloitte Middle East, Dubai, discuss new Saudi Arabia tax guidance, published on June 9, on the mutual agreement procedure (MAP) in tax treaties . . .

Africa

OECD publishes model rules for tax reporting by gig economy platform operators

July 8, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the OECD’s July 3 release of model rules for tax reporting by platform operators. . .

Europe

The Netherlands’ new DAC6 requirements: what multinationals need to know

July 8, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland NV discuss the Netherlands’ DAC6 guidance, released on June 26, and the implications for multinational group taxpayers . . .

Europe

EU to launch tax observatory

July 8, 2020

Francesca Amaddeo a researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the European Commission’s July 6 call for proposals for the creation of an EU tax observatory . . .

Europe

Netherlands announces new policies for resolving cross-border tax disputes

July 7, 2020

Jian-Cheng Ku and Rhys Bane, DLA Piper Nederland N.V., Amsterdam, discuss the Netherlands government’s June 22 announcement of new policies regarding the mutual agreement procedures (MAPs) and arbitration procedures in its tax treaties . . .

Africa

Nigeria clarifies new tax on nonresident digital businesses

July 6, 2020

Gabriel Nwodo and Oluwapelumi Omoniyi of AELEX, Nigeria, discuss a new Nigerian order addressing when a digital business operated by a nonresident company is deemed to have a significant economic presence in Nigeria and is thus subject to tax . . .

Denmark

Denmark Supreme Court rules in favor of Adecco in landmark transfer pricing decision

July 1, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark, discusses the Denmark Supreme Court’s June 25 decision in the Adecco case, a dispute involving the tax deductibility of royalties and the sufficiency of transfer pricing documentation . . .

Europe

Germany announces tax policy goals for Council of the EU Presidency

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses Germany’s July 1 announcement of its tax policy priorities for its six-month Council of the EU Presidency . . .

Americas

First look: Cameco Corp. prevails in landmark in transfer pricing case

July 1, 2020

On June 26, Canada’s Federal Court of Appeal ruled in favor of Cameco Corporation in the transfer pricing . . .

Africa

Draft toolkit on the art of tax treaty negotiation offers tips for developing countries

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .

Africa

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

June 29, 2020

Economist Dr. J. Harold McClure, New York, NY, discusses likely transfer pricing issues associated with Gilead Sciences’ COVID-19 therapy, remdesivir, comparing the transfer pricing treatment of Gilead Sciences’ blockbuster HIV and hepatitis C virus drugs . . .

Europe

Poland poised to launch new corporate income tax regime

June 29, 2020

Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics, discusses the Polish government’s announcement that it will introduce the so-called Estonian solution into Poland’s corporate income tax system . . .

Asia-Pacific

Australia transfer pricing guidance addresses COVID-19 impact

June 24, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium AustralAsia discuss June 9 Australian guidance on the impact of COVID-19 on transfer pricing . . .

Council of the European Union

EU Council agrees to extend DAC6 reporting, financial account reporting deadlines

June 24, 2020

The EU Council today adopted an amending directive allowing EU member states the option to delay by six months the time for filing and exchanging information to meet . . .

Europe

EU Member States agree to defer start date of e-commerce VAT rules

June 24, 2020

EU Member State representatives on Coreper (the Permanent Representatives Committee) today reached . . .

Americas

US Supreme Court lets Altera decision stand: implications for cost sharing and stock options

June 23, 2020

New York economist, Dr. J. Harold McClure, discusses the implications of the US Supreme Court’s June 22 announcement that it would not review the Ninth Circuit panel decision in Altera . . .

Europe

EU Parliament creates permanent tax subcommittee

June 22, 2020

Francesca Amaddeo, Researcher, Tax Law at the Competence Centre (SUPSI), Manno, Switzerland, disccusess the European Parliament’s creation of a permanent subcommittee on tax matters . . .

Africa

The OECD’s “no Plan B” approach on digital taxation backfires

June 22, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, discusses the breakdown of global digital tax talks and the likely future of negotiations . . .

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Asia-Pacific

Updated transfer pricing guidelines in Saudi Arabia

June 17, 2020

Asmae Bazaani of Deloitte Middle East, Dubai, analyzes Saudi Arabia transfer pricing guidelines, issued on June 1, which provide clarifications in several key areas, particularly in relation to documentation requirements and intangibles . . .

Africa

Transfer prices based on EBITDA, not EBIT

June 17, 2020

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

Europe

Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute

June 17, 2020

Michael Vorndran, Nord Advisory AS, Oslo, Norway, discusses a May 28 decision of the Norwegian Supreme Court in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office . . .

Europe

Italy clarifies VAT reporting obligations of online marketplaces

June 16, 2020

Davide Anghileri, a tax researcher with the University of Lausanne, Switzerland, discusses June 1 Italian Revenue Agency guidance clarifying the VAT reporting obligations of online platforms . . .

Americas

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

June 15, 2020

Dr. Harold McClure, a New York economist, analyzes a recent Swedish transfer pricing case, Puma Nordic, and a 2015 Indiana transfer pricing case, Columbia Sportswear, where the transactional net margin method (TNMM) was applied to determine the return of a distribution affiliate . . .

Europe

German cabinet passes stimulus tax measures

June 12, 2020

Berlin tax practitioner, Ninja-Antonia Reggelin, notes today’s passage by Germany’s cabinet of law implementing the tax measures relevant to business, identifying a few changes from the German finance ministry’s earlier draft . . .

Taxing offshore indirect transfers, the Platform’s new toolkit

June 10, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland writes about the Platform for Collaboration on Tax’s June 4 toolkit on taxation of offshore indirect transfers . . .

Europe

Germany proposes substantial VAT rate reduction, tax loss carryback expansion

June 10, 2020

German tax professional Ninja-Antonia Reggelin discusses a German finance ministry draft law released last week addressing tax policy measures relevant for businesses that were agreed to by German coalition parties in a stimulus package earlier this month . . .

Bringing clarity to documenting intercompany financing during a pandemic

June 9, 2020

Harold McClure, a New York, economist, discusses appropriate transfer pricing documentation of financial transactions in the light of the market volatility created by the COVID-19 pandemic. . .

Belgium

Belgium to introduce tax loss carryback, recovery reserve in response to pandemic

June 9, 2020

Geoffroy Galéa, Of Counsel, Head of the Tax Practice, Fieldfisher Brussels, discusses June 5 Belgian government tax proposals aimed at bolstering the liquidity and restoring the solvency of Belgian businesses in the current COVID-19 context . . .

Africa

Senegal cancels tax treaty with Mauritius

June 8, 2020

Moïse Gnakouri, a Doctoral Researcher, Catholic University of Louvain, Belgium, writes about the Senegal government’s decision to cancel its tax treaty with Mauritius . . .

Europe

Netherlands announces plans for new dividend withholding tax

June 4, 2020

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V., Amsterdam, discuss the Dutch government’s May 29 announcement of its intention to propose an additional withholding tax on dividends to step up its fight against tax avoidance . . . .

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

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