Featured News

Americas

US business groups file lawsuit challenging tax inversion regulations

August 4, 2016

Two US business groups today filed a lawsuit in Federal court challenging the validity of US tax regulations aimed at stopping “serial” corporate . . .

Africa

36 non-OECD, non-G20 countries join BEPS international tax effort

June 30, 2016

Thirty-six countries and jurisdictions that are neither OECD nor G20 members have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, and 21 more are expected to join in the coming months, the . . .

EU Parliament approves anti-tax avoidance measure

June 9, 2016

The European Parliament on Wednesday approved the EU Commission’s proposal for an anti-tax avoidance directive aimed at multinational corporations, but said that stricter rules should be applied . . .

Asia-Pacific

First Look: India opens consultation on attribution of profits to PEs

April 19, 2019

The Indian government on April 18 launched a key public consultation into proposed changes , , ,

Europe

EU court’s rejection of French law opens up new opportunity to recover dividend withholding tax

December 5, 2018

Terence Wilhelm of CARA Société d’Avocats, France, discusses taxpayer opportunities that have arisen on account of a November 22 ruling of the Court of Justice of the European concerning the French withholding tax . . .

Bulgaria

Bulgaria proposes its first transfer pricing documentation rules

November 8, 2018

Bulgarian tax practitioner, Ivan Dimitrov, discusses a draft law presented for public discussion on November 5 by the Bulgarian government that would require multinationals to prepare transfer pricing documentation . . .

Europe

Norway State Budget 2019 includes unexpected tax rate reduction, stricter interest deductibility rules

October 16, 2018

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, discusses the Norwegian 2019 state budget, released last week, which contains a number of proposed tax changes that will be of significance to companies in Norway . . .

McDonald’s Luxembourg tax rulings are not illegal state aid even though tax was avoided, Commission concludes

September 19, 2018

The EU Commission today announced that it has determined that tax rulings granted by Luxembourg to McDonald’s in 2009 did not provide illegal state aid to the fast food . . .

Featured News

OECD, UN, IMF, World Bank release revised “toolkit” on taxation of offshore indirect asset transfers

July 17, 2018

The IMF, OECD, UN, and World Bank Group, through a joint initiative known as the “Platform for Collaboration on Tax,” released a revised draft “toolkit” on July 16 that addresses how countries can change their laws to prevent tax-motivated offshore indirect transfers. . .

Digital Economy

G7 leaders agree to work toward resolving dispute over taxing multinational digital firms

June 12, 2018

Following their summit in Charlevoix, Quebec, Canada, held June 8–9, six of the seven G7 leaders pledged to continue to work toward reaching agreement on the taxation of digital multinationals, to collaborate to achieve fair taxation, and continue their efforts to . . .

Europe

UK government stakes out new position on taxation of digital economy

March 13, 2018

Heather Self of Blick Rothenberg, London, provides an analysis of the UK’s updated position paper on the corporate tax and the digital economy, released today as a part of Chancellor Philip Hammond’s Spring Statement . . .

Africa

South Africa proposes to increase VAT rate, subject more foreign electronic services to VAT

February 21, 2018

South Africa’s 2018-19 budget, announced today, proposes the nation’s first VAT rate increase since 1993, raising the VAT from 14 to 15 percent to cover a revenue shortfall. No changes are made to the countries’ 28 percent corporate tax in an effort to maintain South Africa’s competitiveness . . .

Asia-Pacific

India Budget 2018-19 highlights

February 1, 2018

India’s Finance Minister, Arun Jaitley, today released the government’s budget and finance bill. Here is a rundown of tax proposals of particular of interest . . .

Americas

US President signs tax reform into law, SEC follows up with reporting guidance

December 22, 2017

US President Donald Trump today signed the Tax Cuts and Jobs Act into law, which, among other things, slashes the corporate tax rate, and completely changes the US’s international tax system. Securities Exchange Commission staff also followed up today with new guidance on how reflect the impact of the new law in . . .

Asia-Pacific

Australian tax authority finalizes related party financing guidance

December 21, 2017

The Australian Taxation Office on December 18 issued final guidance outlining its compliance approach to related party financing arrangements. Practical Compliance Guideline 2017/4 . . .

Featured News

OECD releases public comment letters on profit split, permanent establishment drafts concerning multinational tax

October 7, 2017

The OECD on October 6 released 44 public comment letters responding to a discussion draft providing guidance on profit splits and 48 public comments on a draft on the attribution of profits to permanent establishments. Both drafts were released June 22 and are designed to set international . . .

Europe

Ireland’s tax treaty position on the OECD multilateral instrument

June 15, 2017

Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .

Americas

Trump’s tax regulation order: what (besides earnings stripping) could be on the chopping block?

April 24, 2017

Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .

Featured News

OECD releases more country-by-country reporting guidance for large multinationals

April 7, 2017

Davide Anghileri of the University of Lausanne discusses OECD tax guidance, released April 6, which further clarifies the country-by-country reporting rules for large multinational groups . . .

EU Commission proposes to speed resolution of double tax disputes

October 25, 2016

The EU Commission has today released a proposed directive designed to strengthen existing mechanisms to resolve tax disputes between EU countries that result in double . . .

Europe

New UK law allows government to introduce public country-by-country reporting by multinationals

September 6, 2016

UK tax professional, Tim Law, discusses the implications of a law passed yesterday that gives the government power to require public country-by-country reporting by multinationals . . .

Belgium

EU Commission publishes decision concluding Belgium’s excess profits tax scheme is State aid

May 4, 2016

The EU Commission today published a non-confidential version of its decision that Belgium’s excess profits tax scheme is illegal under EU State aid rules. The Commission’s decision, first announced in a press release last . . .

Asia-Pacific

Australia sets enhanced cooperation with tax office as condition for foreign investment

February 22, 2016

Australian Treasurer Scott Morrison on February 22 announced that he will use his powers to block investment to force large multinationals and other foreign investors pay tax on Australian . . .

Council of the European Union

Draft German law offers procedures to resolve double tax disputes

April 18, 2019

Tax practitioner Ninja-Antonia Reggelin discusses a German draft law published April 16 providing a scheme for resolving instances of double taxation . . .

Belgium’s excess profits tax scheme is not State aid, EU court concludes

February 14, 2019

Professor and EU tax and state aid expert, Dr. Patricia Lampreave, discusses today’s European General Court decision annulling an EU Commission decision concerning Belgium’s excess profits tax scheme . . .

Americas

Key takeaways from the proposed foreign tax credit regulations

December 19, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, analyze the proposed foreign tax credit regulations released on November 23 . . .

Bulgaria

Bulgaria tax changes introduce first CFC rules, modify thin cap provisions

December 4, 2018

Ivan Dimitrov discusses important tax changes introduced in Bulgaria last week, including the country’s first-ever controlled foreign company (CFC) rules and revisions to the thin capitalization regime . . .

Americas

Five highlights from the IRS’s proposed GILTI regulations

October 1, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, discuss in detail US regulations issued September 13 addressing the new global intangible low-taxed income (GILTI) regime . . .

Americas

New OECD project aims to encourage proper use of tax treaty principal purpose test, official says

June 10, 2018

The OECD is working on a project designed to encourage tax administrations to act reasonably when interpreting and applying the principal purpose test, an official said at the 2018 OECD International Tax Conference, held . . .

Digital Economy

Spain to propose digital services tax beginning 2019

May 9, 2018

The Spanish government has announced it will propose a temporary tax on digital company revenue this year, aiming for the new tax to take effect in 2019, writes Alma Virto. a researcher and PhD candidate at the University of Salamanca, Spain . . .

Americas

Mexico: transfer pricing 2017 year-in-review

January 11, 2018

Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, offer an overview of the most important transfer pricing developments in Mexico in 2017, noting it was a very active year and focusing on new transfer pricing guidance . . .

Europe

Dutch taxation of multinationals: a 2017 year-in-review and look forward to the future

January 8, 2018

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, write that 2017 was a year of significant change for Dutch tax law and international tax law; the authors predict that 2018 will be just as dynamic . . .

Europe

Dutch tax consolidation regime violates EU law, advocate general concludes

November 7, 2017

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .

Featured News

OECD releases cross-border VAT implementation guidance

October 24, 2017

The OECD today released guidance designed to assist policy makers in their effort to evaluate and develop the legal and administrative framework for collecting VAT on cross-border sales. The . . .

Americas

US Republicans propose territorial tax system, global minimum tax

September 27, 2017

US Republican leaders today unveiled an a framework for crafting US tax reform, which includes a cut in the corporate tax rate to 20 percent, a move to a territorial tax system, and a global minimum tax. The Unified Framework for Fixing Our Broken Tax Code, jointly . . .

Featured News

Progress needed on international tax rules for digital companies, OECD’s Saint-Amans says

September 14, 2017

Countries will continue to advance unilateral measures to tax digital businesses unless there is some sign that international consensus can be reached on appropriately taxing these firms, an OECD official warned Wednesday. Speaking during . . .

Africa

BRICS countries agree to coordinate response to G20 international tax work

July 31, 2017

Tax authorities of the five BRICS nations – Brazil, Russia, India, China and South Africa – agreed to enhance their cooperation on international tax matters during the annual meeting of the heads of the BRICS revenue administrations, held . . .

Cyprus

Cyprus adopts key revisions to tax treatment of intragroup back-to-back loans

July 25, 2017

Irish chartered accountant and tax advisor, J.P Canavan, analyzes important changes made to Cyprus’s tax treatment of intragroup back-to-back financing transactions, noting associated remuneration must now comply with the arm’s length principle. . . .

EU VAT proposals for e-books, reverse charge fail

June 16, 2017

The Council of European Union at a meeting today failed to reach agreement on proposals to reduce the VAT rate for electronic publications and temporarily apply a generalised reverse charge mechanism; the EU VAT e-commerce proposal was also discussed, writes Davide Anghileri of the University of Lausanne . . .

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin