What We're Reading–MNE Tax

Multinational

OECD’s Pascal Saint-Amans says patent boxes do not spur IP creation: Charlie Taylor/ Irish Times→

See: Irish Times.

Europe

Google transferred 10.7 billion euros (USD 12 billion) to zero-tax Bermuda through Dutch sandwich in 2014: Toby Sterling & Tom Bergin / Reuters →

February 19, 2016

See: Reuters.

Americas

Apple could face $8 billion tax bill from EU State aid probe: Adam Satariano / Bloomberg Business→

January 19, 2016

See: Bloomberg Business. See also, The Guardian, Business Standard, Fortune, International Business Times, The Independent.

But see: Apple tax bill from EU State aid probe more likely about $200 million, not $8 billion: Tim Worstall / Forbes→

Americas

France’s digital tax may have discriminatory impact on US contrary to trade agreements, official says: Hamza Ali / Bloomberg Tax→

No Picture

EU digital tax compromise plan would apply in 2022, excludes some businesses: Nikos Chrysoloras / Bloomberg→

November 28, 2018

Europe

Netherlands reverses plan to scrap dividend withholding tax opting instead to lower corporate tax rates in 2021 Joost Akkermans and Wout Vergauwen / Bloomberg→

October 16, 2018

Europe

Germany considers requiring Amazon, Ebay to cover unpaid VAT owed by unregistered vendors, sources say: Birgit Jennen & Stefan Nicola / Bloomberg→

Americas

New US guidance permits some MNEs to reduce tax on deemed repatriation: Lynnley Browning / Bloomberg→

Europe

Netherlands to require rulings team to handle all tax rulings with MNEs, will review substance requirement for rulings: Janene Pieters / NL Times→

February 19, 2018

Europe

Apple asks court to ban tax campaigners from its French stores: Angelique Chrisafis / The Guardian→

February 13, 2018

Europe

Italian Parliament weighing equalization tax on intangible digital products, such as advertising: James Politi & Rochelle Toplensky / Financial Times→

November 20, 2017

Asia-Pacific

Kazakhstan government approves tax code amendments: AKIpress News Agency→

September 29, 2017

What We're Reading

Korean government to address MNE tax avoidance, tax digital transactions: Yoon Ja-young / The Korea Times→

August 31, 2017

Americas

US court upholds dismissal of Rand Paul’s FATCA challenge for lack of standing: United States Court of Appeals for the Sixth Circuit→

August 21, 2017

Americas

US JCT staff reviews destination-based tax and border adjustments: Joint Committee on Taxation→

Americas

How France should react to the US border adjustment tax: Gabriel Zucman / LeMonde, Worldcrunch→

See: Worldcrunch.

Interview with Germany’s Kreienbaum, new OECD Committee on Fiscal Affairs chair: EY→

See: EY.

Europe

EU report on transfer pricing valuation techniques released: EU Commission→

January 5, 2017

See: EU Commission report.

No Picture

EU Court of Justice rules in Banco Santader case involving Spanish tax system, State aid: Curia→

December 21, 2016

See: Curia. This ruling will be covered in detail in a future MNE Tax article.

Americas

An inside look at the EU Commision ‘Maxforce team’ focusing on EU State aid enforcement, Apple case: Gaspard Sebag, Dara Doyle & Alex Webb / Bloomberg→

December 19, 2016

See: Bloomberg.

Multinational

Paper addresses R&D tax incentive design: Thomas Neubig, Fernando Galindo-Rueda, Silvia Appelt / OECD→

September 13, 2016

See: Fiscal incentives for R&D and innovation in a diverse world – Papers – OECD iLibrary.

Americas

Kleinbard rejects US corporate dividend integration proposals: SSRN→

See: The Trojan Horse of Corporate Integration by Edward D. Kleinbard –SSRN.

Africa

Zambia retroactively reduces royalty payments payable by mining operators: EY→

See: EY.

Americas

BEPS forces US MNEs to send employees abroad, change commissionaire and double Irish structures: Kevin Bell / Bloomberg BNA→

See: Bloomberg BNA.

Americas

US IRS issue teams must collaborate with APMA on exams involving transfer pricing and treaty partners, IRS manual says: Deloitte→

Asia-Pacific

Sri Lanka adds 3.5 percent tax to online credit card payments: Economynext→

Americas

US’s Mnuchin expresses support for French plan for developed-country minimum tax: France 24→

February 28, 2019

Africa

Angola parliament approves tax treaties with China, Portugal, UAE: Macauhub→

January 30, 2019

No Picture

EU Commission publishes decision concluding McDonald’s Luxembourg tax rulings are not illegal state aid; McDonald’s nontaxation in Luxembourg was due to a mismatch between US and Luxembourg law, not because Luxembourg gave McDonald’s special treatment: EU Commission→

December 18, 2018

Asia-Pacific

Malaysian budget reduces loss carryforwards, adds new tax on imported services: Gavan Ord / INTHEBLACK→

November 6, 2018

United Kingdom

Leaked UK House of Commons paper recommends tax on social media to fund proposals to counter “fake news”: Deccan Herald→

No Picture

EU Commission paying Big Four accounting firms millions to advise on tax policy: Madison Marriage / Financial Times→

Europe

Luxembourg law would add ATAD provisions on CFCs, interest deduction, hybrids and amend anti-abuse, exit tax, PE rules: Loyens & Loeff→

Europe

Draft Swedish law would implement EU anti-tax avoidance directives on hybrid mismatches and interest deductions: Robert Sledz / Thomson Reuters Tax & Accounting→

No Picture

EU Commission open to changing its draft digital taxation proposal: Francesco Guarascio / Reuters→

No Picture

EU Commission to propose “qualified majority” vote on tax matters, including digital firm tax: Francesco Guarascio / Reuters→

October 24, 2017

Asia-Pacific

Turkey to increase corporate tax on financial sector: Reuters→

September 29, 2017

Multinational

Countries should abandon income tax on MNEs, Professor argues: David Elkins / SSRN→

August 28, 2017

Asia-Pacific

Australia focusing tax compliance efforts on pharmaceutical industry: Myriam Robin / Financial Review→

August 28, 2017

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