Africa
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Africa
Digital Economy
Paris consultation reveals little unity on OECD’s “unified approach” for taxing multinational groups
More than 100 speakers lined up at a November 21–22 Paris consultation to share their views on the OECD Secretariat’s compromise proposal to update to the rules for allocating multinational group profits and related taxing rights among countries, known as the “unified approach to pillar one.” The OECD’s . . .
Bulgaria
Asia-Pacific
Europe
Danish staffing company can’t deduct royalties paid to Swiss parent, High Court rules
Peter S. Andersen, Transfer Pricing Partner at Questro International, Amsterdam, analyzes a key decision of Denmark’s Eastern High Court, issued October 28, where the court agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its Swiss parent for the use of marketing intangibles . . .
Digital Economy
Americas
Asia-Pacific
Digital Economy
Featured News
The United Nations’ effort to shape global transfer pricing policy
George L. Salis, Principal Economist and Tax Policy Advisor at Vertex, Inc., King of Prussia, Pennsylvania, discusses the United Nations’ international tax and transfer pricing work, including the outcome of the 19th Session of the UN Committee of Experts on International Cooperation in Tax Matters, held October 15-18 in Geneva . . .
Europe
Americas
Americas
Americas
Americas
Dominican Republic budget proposes new tax on digital services
The Dominican Republic on September 26 issued its budget for fiscal year 2020, proposing new taxes on companies that operate through a digital platform, such as Netflix, Spotify, Airbnb, well as the implementation of country-by-country reporting on large multinationals, writes Elisa Kaminsky, BaseFirma, Miami . . .
Belgium
Digital Economy
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Americas
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Americas
Proposed regs would significantly restrict use of tax losses in US and international M&A transactions
Frank J. Vari, Practice Leader, at FJV Tax Consulting, Boston, Massachusetts, discusses recently released US proposed IRC §382 regulations which would dramatically reduce an acquiring corporation’s ability to use a target’s built-in losses, US net operating loss (NOL) carryforwards, and similar tax attributes following a substantial change in ownership . . .
Americas
Asia-Pacific
Asia-Pacific
Bulgaria
EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to Gibraltar companies from withholding tax
Davide Anghileri of the University of Lausanne, Switzerland, discusses a European Court of Justice Advocate General opinion concerning a Bulgarian law that excludes from the exemption from withholding taxes dividends paid by subsidiary companies incorporated in a Member State to their parent companies incorporated in Gibraltar . . .
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Africa
Digital Economy
Italy’s Council of Ministers make last-minute changes to draft of Budgetary Law 2020
Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland, writes about Italy’s Budget Plan 2020 and related measures, passed by the Council of Ministers with last-minute changes, which includes a digital services tax, environmental and sugar taxes, and measures to thwart tax evasion . . .
Europe
Digital Economy
OECD director, tax experts, explore proposed “unified approach to pillar one” for taxing multinational groups
Julie Martin, managing editor at MNE Tax, discusses the sixth annual Tax Sunday event, held October 20 in Washington, D.C., where the OECD Secretariat’s proposed “unified approach to pillar one” was addressed by OECD tax director, Pascal Saint-Amans and other leading tax experts from government organizations, civil society, business, and academia . . .
Americas
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