What We're Reading

Europe

Irish Finance Minister, in speech, summarizes status of Apple state aid controversy, restates opposition to EU Commission decision: Ireland Department of Finance→

October 6, 2016

See: Statement.

Americas

Gilead Sciences accused of using deferral, other legal loopholes, to reduce US tax : Americans for Tax Fairness→

August 12, 2016

See: Americans for Tax Fairness. More : Stat.

United States

Joint US congressional committee examines patent box tax break: Joint Economic Commitee →

March 11, 2016

See: Joint Economic Committee.

Americas

US has no plans for retaliatory EU tax for state aid decisions, Stack says: Connor Humphries / Reuters→

March 11, 2016

See: Reuters.

Americas

Bermuda likely to be removed from EU list of non-cooperative jurisdictions, finance minister says: Government of Bermuda→

April 9, 2019

Digital Economy

Professors advocate “Residual Profit Allocation by Income” (RPA-I), giving market countries the right to tax residual profit using either of two suggested approaches: Michael P. Devereux, Alan Auerbach, Michael Keen, Paul Oosterhuis, Wolfgang Schön & John Vella / SSRN→

April 1, 2019

Multinational

OECD transfer pricing guidelines should be replaced with improved, simplified methods, professor says: Sol Picciotto / ICTD→

November 14, 2018

Digital Economy

Taxable nexus should be based on the factors of sales, employees, or property in a jurisdiction to address digital economy, professor writes: Monica Gianni / SSRN→

October 3, 2018

Americas

Cayman Islands minister to meet with EU officials about tax blacklist, planning public consultations on new laws requiring substance for tax residence: James Whittaker / Cayman Compass→

September 19, 2018

Americas

US Supreme Court agrees to consider constitutionality of South Dakota law imposing sales tax on online, remote merchants: Greg Stohr / Bloomberg→

January 12, 2018

Europe

Cooper Companies challenging GBP 31 million (USD 42 million) UK diverted profits tax bill: Benjamin Stupples / Bloomberg BNA→

January 12, 2018

Americas

US Senate proposal for minimum tax on foreign intangible income may violate WTO rules: Rebecca Kysar / Medium→

November 13, 2017

Asia-Pacific

Malaysia to propose extension of GST to inbound business-to-consumer digital services: Aina Nasa / South China Morning Post→

September 22, 2017

Europe

UK tax authorities accuse Amazon, eBay of allowing foreign companies to evade UK VAT: Ali Qassim / BNA→

September 14, 2017

Multinational

OECD weighs expanding PE definition for digital presence, alternative tax on sales, Saint-Amans says: Alex M. Parker / Bloomberg BNA→

August 30, 2017

Americas

French finance minister wants more tax from US MNEs: Michel Rose / Reuters→

July 10, 2017

EU report addresses proposal for a common consolidated corporate tax base (CCCTB): EU Parliament→

May 8, 2017

Multinational

Authors analyze treaty shopping, identify key conduit countries: Maarten van ‘t Riet & Arjan Lejour / SSRN→

April 27, 2017

Americas

Authors list DBCFT compromise proposals: Stuart E. Leblang & Amy S. Elliott / TheHill→

March 31, 2017

See: TheHill.

Africa

Paper reviews findings of 9 academics on likely impact of BEPS anti-hybrid rules on Uruguay, Colombia, Brazil, South Africa: SSRN→

March 29, 2017

See: SSRN.

Asia-Pacific

India, Singapore sign tax treaty protocol: Central Board of Direct Taxes→

January 5, 2017

See: Release. The protocol will be analyzed in detail in a future MNE Tax article.

Americas

US Republican lawmakers urge Treasury to issue new proposed section 385 regulations: US House Ways and Means Committee→

October 6, 2016

See: Ways and Means release.

Americas

Indonesia claims Google owes $400 million in 2015 in taxes, fines, for profits wrongly booked in Singapore: Gayatri Suroyo & Eveline Danubrata / Reuters→

September 19, 2016

See: Reuters.

Europe

France won’t cut deal with Google on taxes, may target more MNEs / Reuters →

June 1, 2016

See: Reuters.

Europe

French tax inspectors raid Google offices in tax fraud probe: Michel Rose and Chine Labbé / Reuters→

May 25, 2016

See: Reuters. More: Variety, Financial Times, WSJ.

Belgium

Belgium may abandon push for financial transaction tax: Ian Wishart / Bloomberg→

May 5, 2016

See: Bloomberg.

Americas

Clinton advocates exit tax on corporate inversions on campaign trail: Naomi Jagoda / The Hill→

March 9, 2016

See: The Hill.

Europe

EU’s partial invalidation of UK CFC rules for state aid violations could cost Diageo £278m (USD 362m): Ron Emler / The Drinks Business→

April 9, 2019

Europe

EU Joint Transfer Pricing Forum report addresses application of the profit split method: European Commisson→

March 29, 2019

Americas

US must finalize TCJA international tax regs by June 22 to make them fully retroactive to date of law passage: Siri Bulusu, Isabel Gottlieb, Sony Kassam / Bloomberg Tax→

March 25, 2019

Multinational

Authors analyze OECD draft transfer pricing rules for intragroup financial guarantees: Vera Averyanova & Vikram Chand / Kluwer International Tax Blog→

February 15, 2019

Americas

To avoid EU tax blacklist, BVI approves law requiring financial services firms have offices in the territory: Pedro Gonçalves / International Investment→

January 3, 2019

Asia-Pacific

New Zealand R&D tax incentive bill introduced: Inland Revenue→

October 29, 2018

Digital Economy

Professors say location of “sustained user relationship” should confer taxation rights in digital era: Johannes Becker, Joachim English / SSRN→

October 2, 2018

EU may not be able to police state aid in tax rulings says Advocate General Kokott in interview: Stephen Evans / Delano→

August 1, 2018

Europe

CJEU rules French tax deferral rules on exchange of shares violate EU law: KPMG→

March 27, 2018

Americas

US could defy WTO if it loses EU challenge to FDII, professors say: Reuven S. Avi-Yonah & Martin G. Vallespinos→

February 8, 2018

Europe

German tax office seizes Chinese goods in Amazon warehouse for failure to pay VAT: Florian Kolf / Handelsblatt→

January 8, 2018

Americas

US Senate Finance Committee proposal lowers tax plan’s minimum tax on intangible offshore income to 10 percent for first 10 years: Alex Parker / Law360→

November 16, 2017

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