Professor James Stewart of Trinity College, Dublin, discusses Ireland’s Budget 2017 and the Minister for Finance’s accompanying address, delivered today, which affirmed Ireland’s intent to maintain a low corporate tax rate and address the taxation of financial intermediaries known as section 110 firms . . .
International tax professional, Ninja-Antonia Reggelin, discusses a proposed German law currently under debate that would allow corporations to use losses following a change of shareholders . . .
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Meyyappan Nagappan, a senior member of the international taxation team in the firm’s Mumbai office, discuss new guidance issued by the Indian tax authority to be used to determine the fair market value of indirect transfer of assets, stating that several aspects of the new rules are contentious and could lead to litigation . . .
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational . . .
Carrie Smit, a partner with Goodmans LLP, Toronto, analyzes the Canadian Federal Court of Appeals March 4 decision in The TDL Group Co. v. The Queen, which concluded that a Canadian company is entitled to deduct interest on an intercompany loan used to acquire shares of its US subsidiary. . .
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
The European Commission has opened an in-depth State aid investigation into the UK’s controlled foreign company (CFC) tax laws applicable to multinationals, specifically, the CFC rules’ group financing exception. The group financing exception to the CFC rules, added in 2013, is applicable to multinationals . . .
The Court of Justice of the European Union’s much anticipated judgement in the Mercedes-Benz Financial Services UK Ltd case (Case C-164/16) was delivered on October 4, providing greater clarity on the VAT treatment of personal contract purchase agreements offered by car manufacturers and other companies, as well as on leases in general, writes UK tax specialist, Neil MacKay . . .
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .
EU states must allow a court challenge to the legality of an information order issued to implement a tax-related exchange of information request on the grounds that the request lacks “foreseeable relevance,” the Court of Justice. . .
Enhancing EU tax certainty for multinational groups has become a hot topic. The subject was taken up during a recent informal meeting of the Economic and Financial Affairs Council (ECOFIN) in Malta and is also the focus of a new European Commission taxation paper . . .
An EU Commission proposal to require public country-by-country reporting by multinationals operating in Europe should be extended to cover many more multinationals and to mandate much more robust . . .
A proposed directive for an EU common corporate tax base (CCTB), to be presented by the EU Commission next week, and the EU’s planned common consolidated corporate tax base (CCCTB) proposal, would be mandatory for multinational groups operating in the EU that have annual revenue exceeding €750 million . . .
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss newly issued Notice 2016-52, targeting tax planning undertaken by US multinationals that anticipate large foreign-initiated tax adjustments, noting that the guidance is not limited to adjustments under EU state aid law . . .
Beginning in 2017, the US will stop treating a country as if it has FATCA intergovernmental agreement (IGA) “in effect” if the country does not adequately prove that it has a plan . . .
Countries participating in the OECD/G20 base erosion profit shifting (BEPS) project sought to rewrite international tax rules for the digital economy and for intellectual property to increase their tax take at the expense of the United States, Robert Stack, Treasury deputy assistant secretary. . .
Professor Masao Yoshimura of Hitotsubashi University provides an overview of the corporate tax and transfer pricing changes in Japan’s tax reform 2016, enacted on March 29. . .
Konstantin Sakuth of Linklaters LLP, Munich, provides an update of Germany and France’s plan to jointly develop a common corporate tax base for Europe, noting June 5 comments made by Germany’s Martin Kreienbaum at the OECD Tax Conference in Washington and a May 31 German government announcement on the topic . . .
Davide Anghileri of the University of Lausanne discusses today’s proceedings at the European Union’s Economic and Financial Affairs Council, where the EU’s blacklist of non-cooperative jurisdictions in taxation matters was updated and the ministers voted to approve a Commission proposal requiring mandatory reporting by intermediaries involved with potentially aggressive tax planning schemes . . .
Yuval Navot and Ronen Avner of Herzog Fox & Neeman, Tel Aviv, analyze a tax department circular, published August 23, which interprets new Israeli deemed distribution rules in a draconian manner, making it required reading for multinational taxpayers operating in Israel that extend intercompany loans or guarantees . . .
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