Belgium will add Luxembourg to its tax haven blacklist, writes Luxemberger Wort in June 2 article, quoting Belgian media sources. Such a listing would create hassles for Luxembourg and Belgian companies engaged in cross-border business, as all transactions over 100,000 euros must be reported. See, Luxemburger Wort.
Switzerland’s Federal Council on August 26 announced that it will recommend that Parliament reject a move to heighten bank client confidentiality through the “Yes to the protection of privacy” initiative . . .
A US district court, in the case of Lehman Brothers Holdings Inc. v. US decided May 8, disallowed a US taxpayer’s claim for a foreign tax credit under the US-UK tax treaty for withholding taxes imposed on substitute dividend payments received by its wholly owned US subsidiary from its UK subsidiary pursuant to back-to-back stock loan transactions, EY writes in a May 19 tax alert. See: EY .
The European Commission on February 6 invited interested parties to comment on its state aid investigation into whether an advance pricing agreement (APA) granted by Luxembourg to Amazon that set the price of intra-group royalties. . .
The European Commission on July 13 released a study exploring policy options designed to make the EU VAT system fairer to business engaged in cross-border trade. The EC-commissioned study, prepared by EY, finds t . . .
The UN has released a draft, designed to serve as the basis of discussion at the UN’s Third Annual Conference on Financing for Development, which recommends that the UN Committee of Experts on International Cooperation on Tax Matters be upgraded to an intergovernmental committee. The Committee of Experts, currently a subsidiary body . . .
The US IRS in private letter ruling 201514006 released April 3 has granted a taxpayer consent to change to the elective method and period-by-period identification for purposes of including stock based compensation as an intangible development cost that taxpayer must share for purposes of its cost sharing agreement. See, PLR 201514006.
A coalition of European and American trade unions, joined by the anti-poverty campaign group War on Want, released a report February 24 claiming that McDonald’s avoided over €1 billion (USD 1.1 billion) in European corporate taxes from 2009-2013 by shifting income from its European franchises to a Luxembourg subsidiary through use of royalty payments.The group said that McDonald’s restructured . . .
The European Parliament’s Legal Affairs committee, on May 7, backed a draft law that would require large firms and public-interest entities to publicly report information on a country by country basis, with a goal of strengthening transparency of tax strategies . . .
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
Hong Kong’s Inland Revenue Department, on January 29, released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty . . .
Switzerland’s Federal Counsel. on April 30, announced that the government will prepare a consultation draft on corporate tax reform. The consultation will be based on a government report released December 2013 and will last until September 2014 . See, Press Release.
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.