Europe
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Americas
Americas
Europe
Americas
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Asia-Pacific
China to offer key tax breaks to promote foreign investment
Richard Tan, a partner at Zhong Lun Law Firm, discusses the State Council’s new plan to promote foreign investment into China, presented August 16, which includes withholding tax deferral for reinvested dividends, an extension of the technological service enterprises tax incentive, and a new tax break for overseas income remitted back to China . . .
Council of the EU
Americas
Trump budget advocates territorial tax system, omits border adjustment
US President Trump today released his first budget, presenting tax proposals that echo the principles that the Administration . . .
Europe
German tax law denying corporate loss carryforward is unconstitutional, court rules
A German court has struck down portions of a controversial law that denies tax loss carryforwards following a change of shareholders, ruling that the provisions are unconstitutional, writes international tax practitioner Ninja-Antonia Reggelin . . .
Featured News
OECD lists countries agreeing to country-by-country reporting exchange
The OECD today released an updated list of automatic exchange relationships established between tax authorities to implement country-by-country reporting under Action 13 of the OECD/G20 base erosion profit shifting (BEPS) plan. The OECD also announced activation of automatic . . .
Featured News
New UN extractives industry guidance note analyzes value chain for mining, oil and gas
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
Europe
Switzerland: withholding tax exemption adopted to facilitate intragroup financing
Switzerland’s parliament, on March 10, approved a withholding tax exemption for intragroup interest payments, writes Davide Anghileri of the University of Lausanne. . .
Featured News
World Bank publishes transfer pricing handbook for developing countries
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
Featured News
OECD releases discussion drafts on attribution of MNE profits to permanent establishments and profit splits
The OECD today released two discussion drafts on international tax standards that deal with allocating multinational corporation profits between tax jurisdictions: guidance on the attribution of profits to permanent establishments (PEs) and proposed revisions to guidance on profit splits under the OECD . . .
Austria
EU finance ministers split on public release of multinational corporation tax data
Dutch finance minister and president of the Eurogroup, Jeroen Dijsselbloem, expressed support for a proposal that would mandate public release of country-by-country tax data on multinationals, while finance ministers from Malta, Belgium, and Austria . . .
Europe
Germany details tax rules for international businesses with permanent establishments
Tax specialist, Ninja-Antonia Reggelin, reviews a new German circular providing comprehensive guidance on the allocation of profits between a business and a foreign permanent establishment . . .
Featured News
2016 US model tax treaty differs significantly from draft version, practitioners say
US Treasury has published an updated US model tax treaty, making significant revisions to the text of draft treaty provisions released last May. The 2016 US Model Income Tax Convention, published on Wednesday, will be . . .
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Featured News
Part two: international tax consultation on “digitalization” draws 50 speakers (pillar two)
Part two of two. This article summarizes discussion of the “pillar two” proposals at the OECD digitalization consultation, held March 13–14 in Paris. The pillar two proposals, described in a February 13 OECD discussion draft, call for global adoption of a minimum tax and a tax on base eroding payments. . . .
Europe
Asia-Pacific
Asia-Pacific
Americas
Denmark
Africa
UK requires companies in Caymans, BVI, other territories, to publicly disclose ownership
Britain’s overseas territories, including the tax havens of Cayman Islands, British Virgin Islands, and Bermuda, must introduce publicly accessible registers of the beneficial ownership of companies located in their jurisdictions before 2021 or the UK will require them to do so, a law approved by UK Parliament . . .
Europe
EU proposal takes aim at letterbox companies established to avoid tax
The European Commission today proposed harmonized rules that would prevent companies from moving their registered offices to letterbox companies located in other EU countries thereby creating undue tax advantages. Similar rules are provided for cross-border company divisions. The EU proposals are part of a package of company law rules . . .
Belgium
Belgium: Fairness Tax struck down by Constitutional Court
Daniel Garabedian and Steven Peeters of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss the implications of a March 1 decision of Belgium’s Constitutional Court, which struck down Belgium’s Fairness Tax as unconstitutional, but also left the tax partially in place for a temporary period . . .
Asia-Pacific
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Europe
Europe
Switzerland seeks automatic exchange of tax information with 41 more countries
Switzerland has decided to pursue automatic exchange of financial account information arrangements with 41 more countries, writes Davide Anghileri of the University of Lausanne . . .
Europe
German guidance clarifies withholding tax on cross-border software, databases
International tax attorney Ninja-Antonia Reggelin discusses German guidance issued May 17 detailing the limited tax liability and source taxation of cross-border transfers of software and databases . . .
Featured News
2017 UN transfer pricing manual released, changes approved for model tax treaty
The UN’s Committee of Experts on International Cooperation in Tax Matters (UN Committee), during meetings held last week, released its revised and updated 2017 United Nations Practical Manual on Transfer Pricing for Developing . . .
Europe
Italy’s Supreme Court rules French holding company has sufficient substance for tax purposes
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Americas
Switzerland weighs expansion of automatic exchange of tax information to 20 more countries
Davide Anghileri of the University of Lausanne discusses Switzerland’s decision to launch a consultation on automatic exchange of information with 20 more countries . . .
Australia
Australian tax agency offers multinationals guidance on tax risk management and governance
Davide Anghileri of the University of Lausanne writes about Australian Taxation Office guidance published January 27 designed to help foreign multinationals and other taxpayers understand the ATO’s views on what better tax corporate governance practices look like so companies can develop or improve their own tax governance and internal control framework . . .
Europe
France: public county-by-country reporting declared unconstitutional
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
Americas
US, Mexico agree to transfer pricing framework for maquiladoras
The US IRS today announced agreement with Mexico on a transfer pricing framework for US multinational enterprises that have maquiladora operations which, if applied in . . .
