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Digital Economy

Comments released on OECD model rules requiring reporting by digital platforms to assist tax administration

April 15, 2020

The OECD today released comments received in response to draft model rules that would require platform operators to report on income . . .

Africa

Transfer pricing issues arising from the COVID-19 pandemic

April 14, 2020

Gaurav Jain, an India chartered accountant, and Priya Mani Bhutani, a New Delhi transfer pricing professional, discuss the impact of the COVID-19 crisis on transfer pricing . . .

Europe

Swedish court rules against Flir Systems, upholds tax penalties of EUR 70 M (USD 76.5 M)

April 13, 2020

Emiliha Ferrão and Madeleine Thörning, of Thorning Koponen Consulting, Stockholm, discuss a recent Swedish Administrative Court decision in Flir Systems, where the court upheld the Swedish tax agency’s conclusions regarding the tax due on the sale of IP owned by Flir Systems’ Belgium PE to a related Belgian company and also upheld the tax agency’s imposition of significant tax penalties . . .

Africa

OECD issues welcome guidance on tax treaty issues arising from the COVID‑19 crisis

April 13, 2020

Jian‑Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi of DLA Piper Nederland N.V., Amsterdam, discuss April 3 guidance released by the OECD Secretariat addressing how governments should apply standard tax treaty provisions when multinational group taxpayers or their employees are forced to change their behavior to comply with COVID‑19 travel restrictions and quarantines . . .

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Americas

First Look: US IRS publishes final and proposed regulations on hybrid mismatches

April 8, 2020

The US IRS today published final (T.D. 9896) and proposed (REG-106013-19) regulations on hybrid arrangements. Hybrid . . .

Denmark

Denmark extends all filing deadlines, including those for transfer pricing documentation

April 8, 2020

Michael Vorndran of Nord Advisory AS, Oslo, Norway, writes that the Danish Ministry of Taxation announced in a press release that all tax filing deadlines for the 2019 income year will be postponed, including transfer pricing documentation deadlines . . .

Europe

Luxembourg introduces transfer pricing documentation requirement for controlled foreign company compliance

April 8, 2020

Danny Beeton of Arendt & Medernach, Luxembourg and London, discusses a Luxembourg Tax Administration circular letter which sets out their detailed view of how the Luxembourg tax law applies to controlled foreign companies . . .

Featured News

OECD lists tax policy measures enacted by 90 countries in response to COVID-19 pandemic

April 8, 2020

The OECD Secretariat has published a spreadsheet listing more than . . .

Featured News

Dutch corporate tax residency and substance may be affected by COVID-19 quarantine and travel restrictions

April 6, 2020

Jian Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam discuss the potential impact on multinational group taxation if companies follow Dutch restrictions on public gatherings and travel in response to the coronavirus emergency, including the effect on Dutch substance and tax residency provisions, . . .

Featured News

First Look: OECD considers impact of COVID-19 mobility restrictions on tax treaties

April 4, 2020

The OECD Secretariat on April 3 issued guidance on how countries’ restrictions on mobility due to the COVID-19 pandemic affect . . .

Americas

OECD should pause digital tax negotiations, US business group says

March 31, 2020

In a letter to Treasury Secretary Steven Mnuchin, the United States Council for . . .

Asia-Pacific

India’s tax response to coronavirus

March 29, 2020

Ritu Shaktawat, a tax partner at Khaitan & Co, Mumbai, discusses tax measures announced by the Indian government on March 24 in response to the coronavirus pandemic . . .

Africa

South Africa provides assistance to small businesses and employees through tax system

March 24, 2020

Jana Botha, a consultant in the tax practice at Baker McKenzie Johannesburg, discusses tax measures announced on March 23 by South Africa’s government aimed at supporting individuals and small businesses amid the coronavirus emergency . . .

Europe

Netherlands enacts tax measures in response to COVID-19

March 19, 2020

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V., discuss measures announced by the Dutch government on March 12 and March 17 in response to the COVID-19 pandemic . .

Asia-Pacific

Australian High Court clarifies definition of “associate” in BHP Billiton tax dispute

March 19, 2020

Paul McNab, a Tax Controversy Partner at PwC Sydney, discusses the March 11 decision High Court of Australia in BHP Billiton Limited v Commissioner of Taxation [2020] HCA 5) where the Court addresses the definition of “associate” for tax purposes . . .

Europe

France enacts emergency tax measures in response to coronavirus epidemic

March 18, 2020

Pascal Luquet and Mickaël Duquenne of Grant Thornton Société d’Avocats, Neuilly-sur-Seine, discuss emergency tax measures, announced by the French General Directorate of Public Finance, enacted in response to the coronavirus epidemic. . .

Featured News

Nigeria’s Tax Appeal Tribunal decides Prime Plastichem transfer pricing case

March 16, 2020

Chizaram Modline Oparaji of Deloitte Middle East, Dubai, discusses a Nigerian Tax Appeal Tribunal decision, delivered February 19, finding in favor of the tax authority in a dispute over Prime Plastichem Nigeria Limited’s transfer pricing method . . .

Featured News

Poland issues controversial transfer pricing risk assessment rules

March 12, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at Warsaw School of Economics discusses new Polish rules requiring multinational groups to disclose additional information to the tax office for use in transfer pricing risk assessment . . .

Europe

UK Budget 2020: an overview of the tax proposals

March 11, 2020

Nimesh Shah, a Partner at Blick Rothenberg, London, provides an overview of the tax changes introduced in the UK budget, released today . . .

Europe

Norway proposes new withholding tax on some related-party payments

March 11, 2020

Michael Vorndran of Nord Advisory AS, Oslo, discusses a Norway Ministry of Finance proposal, issued on February 27, for a 15% withholding tax on interest, royalty, and lease payments to non-resident related parties. . . .

Africa

OECD releases 79 public comments responding to review of country-by-country reporting scheme

March 9, 2020

The OECD today released 79 comment letters it received in response to its consultation on a 2020 review of the country-by-country reporting rules . . .

Digital Economy

The Vodafone and Tesco Global decisions: no triumph for EU digital services tax supporters

March 5, 2020

Dr. Leopoldo Parada, Lecturer in Tax Law at the University of Leeds School of Law, discusses March 3 CJEU decisions in cases brought by Vodafone and Tesco Global which could affect the legality under EU law of digital services taxes . . .

Asia-Pacific

Georgia transfer pricing: what multinational groups need to know

March 5, 2020

Gela Barshovi, Tax Advisor and Managing Partner at TPsolutions, Tbilisi, Georgia, provides an overview of Georgia transfer pricing laws and the Georgia tax administration’s practices regarding transfer pricing . . .

Africa

South Africa 2020 Budget proposes new limits on interest deductions, loss carry-forwards

March 4, 2020

Virusha Subban, Jana Botha, and Prenisha Govender of Baker McKenzie, Johannesburg, discuss South Africa’s 2020 budget, released last week, which announces government proposals to alter the tax rules affecting multinational groups . . .

Europe

Italy enacts tax relief to cushion Coronavirus emergency

March 2, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses emergency tax measures enacted by Italy’s Council of Ministers yesterday evening that are aimed at reducing the economic harm caused by the Coronavirus. . .

Asia-Pacific

Singapore Budget 2020 extends and enhances business tax breaks

February 24, 2020

Eugene Lim, Sam Sim, and James Yeo of Taxise Asia LLC (member of WTS Global), Singapore, discuss Singapore’s Budget 2020, released February 18, which includes tax incentives and other tax provisions of interest to foreign investors . . .

Asia-Pacific

India’s Authority for Advance Rulings denies tax exemption under India-Mauritius treaty

February 24, 2020

Ritu Shaktawat, a partner at Khaitan & Co, Mumbai, India, discusses a controversial ruling released February 17 by India’s Authority for Advance Rulin which denied a capital gains tax exemption under the India – Mauritius tax treaty to a Mauritian entity . . .

Digital Economy

G20 finance ministers say “unified approach” should be basis for negotiating updated tax rules for multinationals

February 23, 2020

G20 finance ministers and central bank governors, at their meeting in Riyadh, Saudi Arabia, held February 22–23, said they welcomed recent progress made by countries toward reaching . . .

Africa

Extending transfer pricing benchmarking’s geographic scope: some thoughts on the TPED study

February 18, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, comments on a December study published by the Transfer Pricing Economists for Development (TPED) that presents a new framework for selecting and adjusting foreign comparables . . .

Africa

EU blacklist: Cayman Islands added with other three jurisdictions

February 18, 2020

Davide Anghileri, a researcher at the University of Lausanne, writes that during today’s meeting, the EU Council added four countries to the EU list of non-cooperative jurisdictions for tax purposes and removed 16 countries from the gray list . . .

Digital Economy

Spanish government approves digital services tax targeting large multinationals

February 18, 2020

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid, discusses a bill for a digital service tax approved today by the Spanish government . . .

Featured News

The final OECD transfer pricing guidelines for financial transactions: what has changed?

February 18, 2020

Casimir Leuridan and Melanie Beirens of Zanders, Belgium, analyze the long-awaited OECD transfer pricing guidance on financial transactions, released February 11 . . .

Americas

Impact of global tax reform effort remains unclear, senior congressional staff members say

February 18, 2020

It is unknown whether the proposed update the international system for taxing multinationals, advanced by the OECD, will benefit or harm US interests, senior staff to Congress’ tax-writing committees said at Tax Council Policy Institue conference, held in Washington DC . . .

Europe

Spain to scrutinize taxpayers’ transfer pricing positions

February 17, 2020

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss new Spanish guidance which describes the international tax and transfer pricing issues that the tax authorities will focus their enforcement efforts upon in 2020 . . .

Digital Economy

Global tax rewrite could cost multinationals USD 100 billion annually, OECD says

February 13, 2020

Global corporate income tax due from multinational groups could increase by up to 4 percent or by about USD 100 billion annually if tax reforms currently being considered by 130+ countries are adopted, OECD officials said today during a presentation . . .

Africa

First look: OECD publishes transfer pricing guidance on financial transactions

February 11, 2020

The OECD today published its long-awaited transfer pricing guidance on financial transactions, notes Melanie Beirens, Senior Consultant, Zanders, Belgium . . .

Europe

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

February 11, 2020

Erik Koponen and Madeleine Thörning, transfer pricing specialists at Thorning Koponen Consulting, Sweden, discuss a recent Swedish tax agency decision rejecting a Puma subsidiary’s transfer pricing position following the approach to risk taken in the OECD transfer pricing guidelines . . .

Europe

EU court assesses legality of Netherlands’ denial of German UCITS’s dividend withholding tax refund

February 11, 2020

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, analyze the European Court of Justice’s January 30 decision in the Köln-Aktienfonds Deka case concerning the legality of the Netherlands’ refusal to grant a German investment fund a dividend withholding tax refund . . .

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