Europe
Featured News
Featured News
Europe
Council of the European Union
Europe
Americas
Cayman Islands financial institutions to face new CRS reporting thresholds, self-cert requirements
Denise Hintzke and Douglas Scott of Deloitte Tax LLP discuss recent, significant changes made to the Cayman Islands common reporting standard (CRS) regime for financial institutions, including an expansion of the pool of persons subject to Cayman CRS reporting and a new process for entity self-certification . . .
Africa
Americas
Swiss advance information exchange for tax purposes with Singapore, Hong Kong, other financial centres
Davide Anghileri of the University of Lausanne discusses the Swiss government’s progress advancing exchange of financial account information for tax purposes with Singapore, Hong Kong, and several countries, including Bahamas and Bahrain, that apply automatic exchange in a non-reciprocal manner . . .
Featured News
Europe
Asia-Pacific
China introduces Circular 88, offering new dividend withholding tax exemption to encourage foreign investment
David Dingfa Liu, a partner with FuJae Partners, Shanghai, discusses Circular 88, a tax incentive introduced by the Chinese government on December 21 that allows multinationals to defer withholding tax which would otherwise be imposed on dividends distributed to foreign investors when the dividends are reinvested in China. . . .
Europe
Africa
Asia-Pacific
High Court rules India can’t tax Dutch company’s sale of shares in Indian company that holds Indian immovable property
Joachim Saldanha and Ashish Sodhani of Nishith Desai Associates discuss a recent Indian High Court decision which concludes that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company are not taxable in India under the India-Netherlands tax treaty . . .
Featured News
Europe
New Germany-Switzerland tax arbitration agreement provides legal certainty
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
Denmark
EU court to consider beneficial ownership definition for interest and royalty directive
The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .
Asia-Pacific
Singapore budget 2017 includes new IP regime, other tax changes
Davide Anghileri of the University of Lausanne provides an overview of the tax proposals of interest to multinationals in Singapore’s budget, presented to parliament on February 20, . . .
Asia-Pacific
No changes planned for India-Netherlands tax treaty but BEPS multilateral instrument looms
Sriram Govind of the Institute for Austrian and International Tax Law discusses reports that India will not renegotiate its tax treaty with the Netherlands, as it did with Mauritius, Cyprus, and Singapore, and addresses the impact of the countries’ expected signing of the BEPS multilateral instrument . . .
Europe
EU scrutinizing Luxembourg tax rulings on intercompany convertible loans for state aid
The European Commission today made it clear that it is not bowing to political pressure to halt its investigation into EU states that grant private tax deals to multinationals, announcing a probe into Luxembourg tax rulings granted to French energy company Engie, formally . . .
Americas
US, Luxembourg agree to tax treaty changes to prevent double nontaxation
The US Treasury Department today announced that the US and Luxembourg, during negotiations for new protocol to their 2000 tax treaty, have agreed to provisions to address tax avoidance through triangular and exempt permanent . . .
Europe
EU countries strike deal on anti-tax avoidance directive aimed at multinationals
The European Union has reached political agreement on a directive designed to combat multinational corporation tax avoidance, with all 28 countries signing on. . .
Europe
New Dutch guidance addresses dividend withholding tax refund due foreign shareholders
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, discuss new Dutch guidance on withholding tax refunds due foreign shareholders following the Dutch Supreme Court’s decision in Miljoen, X, and Société Général . . .
Digital Economy
Asia-Pacific
Asia-Pacific
India developing “significant economic presence” test to increase taxation of multinational firms
Nishith Desai Associates attorneys, Meyyappan Nagappan and Anandapadmanabhan Unnikrishnan, discuss the Indian government July 13 request for public feedback to aid in the development of a “significant economic presence” test, which is a nexus rule designed to expand India’s taxation rights over business profits of both digital and non-digital multinational firms . . .
Asia-Pacific
Indian tax tribunal adopts expansive view of permanent establishment in Mastercard ruling
India’s tax authority has won a sweeping victory before India’s Authority for Advance Rulings, convincing the tribunal on 6 June that Mastercard’s activities in India created a permanent establishment in India under several different theories, write Nishith Desai Associates attorneys Shipra Padhi and Anandapadmanabhan Unnikrishnan . . . .
Featured News
Europe
Featured News
Council of the EU
Europe
Asia-Pacific
Indian flavors in transfer pricing master file, country-by-country rules
Jitendra Jain, Executive Director at PricewaterhouseCoopers, India, discusses India’s much-awaited rules on the implementation of the master file and country-by-country report, released yesterday, focusing on the differences between India’s master file requirement and the OECD’s prescribed format and recommending next-steps to comply with the requirements . . .
Americas
Europe
EU Parliament approves public country-by-country for multinationals
Today, the EU Parliament approved a proposal for a directive of the European Parliament and of the Council amending Directive 2013/34/EU as regards the disclosure of income tax information by certain undertakings and branches, writes Davide Anghileri of the University of Lausanne . . .
Europe
EU Presidency offers compromise proposal for public country-by-country tax reporting by multinationals
Malta, as holder of the EU Presidency, has offered a compromise proposal to the EU Council that would require large multinational enterprises to publicly disclose tax information on a country-by-country basis, writes Davide Anghileri of the University of Lausanne . . .
Europe
French rule denying tax deferral on merger is contrary to EU law, court rules
JP Canavan discusses the EU Court of Justice’s highly anticipated decision in the Euro Park Service case, which further defines the limits of EU Member States’ ability to restrict tax deferral benefits on mergers, reorganizations, and similar transactions . . .
Americas
US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Europe
EU publishes CCTB, CCCTB, ATAD II directives proposing major tax reform for multinationals
Paulus Merks, Jian-Cheng Ku, and Jesse Peeters of DLA Piper, Amsterdam, discuss today’s release by the EU Commission of three tax directives, the CCTB, CCCTB, and ATAD II, which will potentially have a significant impact on multinationals operating in the European Union . . .
