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Brazilian tax authority rules cross-border payment for software as a service (SaaS) subject to withholding
Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service’s opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .
Asia-Pacific
Belgium
Belgium fairness tax system may violate EU law, court rules
Davide Anghileri of the University of Lausanne discusses a May 17 European Court of Justice decision finding that Belgium’s fairness tax system is incomparable with EU freedom of establishment concepts and the parent-subsidiary directive . . .
Americas
Trump proposes 15 percent corporate tax rate, territorial tax system
President Trump on Wednesday unveiled his tax plan, proposing steep reductions in both individual and corporate income tax rates as well as a move to a territorial tax . . .
Featured News
Italy clarifies patent box, R&D tax credit, business assets credit
Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy’s patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .
Europe
Italy adds Switzerland to financial transactions tax white list
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses the implications of Italy’s decision to put Switzerland on its white list for purposes of the financial transactions tax . . .
Europe
New rules require businesses with large UK operations to publish tax strategy on internet
Sandy Bhogal and Kitty Swanson, of Mayer Brown, London, discuss the details of new UK rules that require large businesses to publish a tax strategy on the internet, noting several concerns with the provision . . .
Europe
Leaked EU directive for public country-by-country reporting allows aggregation of third country tax data
A proposed EU directive would require public country-by-country reporting by multinationals on worldwide operations broken down by EU member states, but disclosure of only aggregated data for non-EU operations, according to a leaked. . .
Europe
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Africa
Digital Economy
Europe
Europe
Americas
Bahamas, US Virgin Islands, Saint Kitts to be added to EU tax blacklist, leaked document says
The Bahamas, US Virgin Islands, and Saint Kitts and Nevis will be added to the EU’s blacklist of non-cooperative third-country tax havens on March 13 during an EU finance ministers meeting, Reuters has reported, citing a leaked EU document dated March 8. This latest leak follows a widely-reported earlier leak that . . .
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Americas
Europe
Americas
US to repeal or revise debt-equity regulations, other tax guidance, under Trump order
US Treasury has identified eight tax regulations — including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations — as qualifying for revision under President Trump’s executive order mandating a reduction in . . .
Featured News
The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .
Europe
Luxembourg transfer pricing bill would adopt some BEPS changes
Dr. Paloma Schwarz Martínez, University of Luxembourg, discusses a new bill under consideration by Parliament that would incorporate some of the BEPS transfer pricing changes into Luxembourg law . . .
Europe
EU Commission publishes decision to extend Gibraltar state aid probe to tax rulings
The European Commission has published a non confidential version of its decision to open an investigation into whether Gibraltar’s tax ruling practice violates . . .
Europe
Tax officials address joint audits, public country-by-country reporting, developing country tax incentives
Tax experts, including officials from Germany, the IMF, World Bank Group, and OECD, offered their views on joint audits for multinational corporations, public country-by-country reporting, and tax incentives offered by developing countries at a conference held . . .
Belgium
Belgium’s excess profit tax ruling system: why the Commission thinks it’s illegal State aid
Professor Edoardo Traversa and Pierre Sabbadini analyze the EU Commission’s decision, made public May 5, that Belgium’s excess profit rulings tax scheme is illegal under State aid rules. . .
Asia-Pacific
Australian tax office seeking to fast-track key court disputes with multinationals
The Australian Tax Office (ATO) is working with the Federal Court in an effort to “fast-track” the resolution of strategically important tax cases, Tax Commissioner Chris Jordan said April 21 at a Senate committee hearing on multinational corporation . . .
Featured News
Countries that accept BEPS minimum standards may participate in global tax effort, OECD says
Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according . . .
Featured News
Countries approve OECD proposal on VAT/GST collection by digital platforms
MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, discusses the fifth Global Forum on VAT meeting in Melbourne, held March 20-22, where more than 100 jurisdictions, endorsed an OECD report on the role of digital platforms in the collection of VAT/GST on online sales . . ..
Digital Economy
Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)
More than 50 international tax and transfer pricing experts from business, academia, labor, and non-governmental organizations spoke at a March 13–14 consultation, held at the OECD in Paris, on the tax challenges of digitalization. This article addresses the first day of the consultation which concerned the “pillar one” policy proposals . . .
Asia-Pacific
Americas
Americas
