From the Firms–MNE Tax

Asia-Pacific

Australia to impose GST on digital products, low value imported goods: EY→

June 29, 2017

Swedish ruling concludes parent-subsidary directive anti-avoidance rule inapplicable to dividend distribution to Maltese parent: EY→

May 17, 2017

Americas

Disallowance of US loss from worthless Russian sovereign debt upheld on appeal, purchase lacked substance: Steptoe & Johnson→

March 15, 2017

See: Steptoe & Johnson.

Africa

South Africa considers crackdown on tax avoidance through hybrid debt: EY→

May 16, 2016

See: EY

Asia-Pacific

Japan’s tax agency issues Q&A on mutual agreement procedure: KPMG→

October 5, 2017

Asia-Pacific

EU, Japan sign agreement to remove, reduce tariffs: KPMG→

July 17, 2017

Europe

Norway considers more interest deduction limits: Deloitte→

May 8, 2017

Europe

EU Court to assess whether foreign investment funds are entitled to Dutch dividend withholding tax refund: Deloitte→

March 15, 2017

See: Deloitte. More: EY, Loyens & Loeff.

Africa

South Africa issues draft regulations on country-by-country reporting: KPMG→

April 15, 2016

See: KPMG

Americas

US Senate and House tax bill differences to be resolved by conference committee: Steptoe & Johnson→

December 5, 2017

Austria

Austrian Supreme Court addresses taxation of corporate groups: KPMG→

October 5, 2017

Asia-Pacific

Israel circular calls for deemed dividend upon company withdrawals: EY→

September 23, 2017

Czech Republic

Czech proposal would implement country-by-country reporting: KPMG→

April 20, 2017

Americas

Austrian holding companies without substantial economic activities are ‘privileged tax regimes,’ Brazil concludes: KPMG→

January 18, 2017

See: KPMG.

Asia-Pacific

China releases report on 2015 advance pricing agreement program: EY→

January 12, 2017

See: EY.

Europe

French Parliament approves bill providing for diverted profits tax: EY→

December 23, 2016

See: EY.

Europe

French court in Valueclick rules that Irish company’s French employees did not create permanent establishment: KPMG→

March 14, 2018

From the Firms

World Customs Organization examines effect of transfer pricing report on price for imported goods: KPMG→

November 16, 2017

Asia-Pacific

Taiwan to extend VAT to foreign suppliers of e-commerce services: EY→

March 31, 2017

See: EY.

Europe

Luxembourg adopts exchange of information on cross-border rulings: EY→

May 6, 2016

See: EY

Asia-Pacific

Paper addresses allocation of income attributable to a PE based on digital presence with a focus on Indian law: PWC→

June 26, 2018

Americas

US court concludes foreign tax refund challenged by tax authorities still reduces FTCs: PWC→

June 19, 2017

Europe

UK transfer pricing disputes rose substantially in 2016: Out-Law.com→

June 8, 2017

Asia-Pacific

Australia to require nonresident retailers, platforms to register for GST: PWC→

February 22, 2017

See: PWC.

Asia-Pacific

Australian law requires local file in electronic format, no transfer pricing report: PWC→

June 14, 2016

See: PWC

Europe

Jersey introduces limited liability company law aiding cross-border structuring: Jersey Finance→

September 25, 2018

Europe

Luxembourg bill ratifies MLI, opting for principal purpose test, arbitration, some hybrid and PE rules: Loyens & Loeff→

July 8, 2018

Asia-Pacific

South Korea suspends plan to lower ownership threshold for withholding capital gains of share sales by foreigner investors: Yulchon LLC / Lexology→

February 12, 2018

More: Dahee Kim, Cynthia Kim / Reuters→

Europe

Poland enacts significant corporate tax reform, limiting deductions, adding thin cap, CFC rules: EY→

November 28, 2017

Europe

German court rules nonresident without PE is exempt from tax on gain on sale of German shares: Deloitte→

November 5, 2017

Africa

Nigeria revises list of industries eligible for pioneer status tax incentive: EY→

August 15, 2017

Asia-Pacific

Singapore allows cost-plus mark-up basis for routine services: KPMG→

May 11, 2017

Americas

Proposed Colombia tax law overhaul includes corporate tax simplification, increases to tax base, adds dividend withholding tax: KPMG→

October 24, 2016

See: KPMG.

Asia-Pacific

New Turkish transfer pricing law is consistent with OECD guidelines: KPMG→

September 13, 2016

See: KPMG.

Asia-Pacific

Australia proposes to amend “significant global entity” definition: KPMG→

July 25, 2018

Asia-Pacific

Malaysian budget proposes BEPS Action 4 interest deduction limits for related-party debt: Wong & Partners→

November 5, 2017

Europe

Polish bill would substantially change corporate income tax scheme: EY→

July 13, 2017

Asia-Pacific

Japan clarifies country-by-country reporting notification requirements: EY→

February 22, 2017

See: EY.

Asia-Pacific

Australia hybrid mismatch law passes parliament, awaits Royal Assent: EY→

August 18, 2018

RECENT COMMENTS

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
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

Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.

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