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Europe
UK draft tax legislation would modify carried-forward loss rules, limit interest deductions
Julian Feiner of Dentons, London, discusses draft UK proposals, released yesterday, that would change the taxation of carried-forward losses and interest deductions . . .
Europe
Featured News
OECD draft examples address tax treaty “principal purpose test” for non-CIV funds
The OECD has today released for public comment three draft examples addressing the application of the OECD/G20 base erosion profit shifting (BEPS) Action 6 principal purpose test to . . .
Americas
US FATCA IGAs with Panama, Georgia enter into force; IGA with Antigua and Barbuda signed
The US Treasury Department today updated its FATCA website, reporting that Model 1 intergovernmental agreements (IGAs) entered . . .
Americas
Mark Trivette joins Alvarez & Marsal Taxand’s Atlanta office
Mark Trivette has joined Alvarez & Marsal Taxand, Atlanta, as its new Managing Director . . .
Europe
EU Commission to draft financial transaction tax legislation
The EU Commission has been asked to prepare draft legislation for a financial transaction tax (FTT) following significant progress made on the design of the tax . . .
Asia-Pacific
Japan, Belgium sign tax treaty
Japan and Belgium today signed a new tax treaty, Japan’s Ministry of Finance . . .
Americas
US Democrats introduce bill to close foreign reinsurance tax loophole
US Democrats on Wednesday introduced a bill designed to prevent foreign insurance groups from avoiding US tax by paying reinsurance premiums to affiliates located in tax . . .
Americas
Americas
US criticizes EU probe of multinational corp tax as Apple decision nears
The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .
Multinational
Asia-Pacific
China makes major changes to transfer pricing documentation and reporting rules for multinationals
Daniel Chan, Windson Li, and Henry Ji, of DLA Piper, Hong Kong, provide a comprehensive overview of key Chinese transfer pricing documentation, inter-company transaction reporting, and country-by-country reporting rules, which were adopted on July 13 . . .
Europe
Ireland’s tax authority issues FAQs on country-by-country reporting
Irish Revenue on June 23 issued a set of frequently asked questions regarding new Irish tax legislation and regulations that require country-by-country reporting by . . .
Americas
Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs
Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .
Asia-Pacific
Europe
Finland and Portugal agree to terms of new tax treaty
Finland’s Ministry of Finance today announced that it has reached an agreement with the Portuguese government on the terms of a . . .
Featured News
IMF, OECD, UN, and Word Bank Group to jointly work on multinational business tax issues
The International Monetary Fund, OECD, United Nations, and World Bank Group today released a concept note outlining their plan to work together to help governments address the tax policy . . .
Americas
Europe
UK’s HMRC details new requirement for large businesses to publish tax strategy
The UK’s HM Revenue and Customs (HMRC) on March 31 published draft guidance describing new rules that will require large companies, partnerships . . .
Africa
Europe
Dutch court clarifies dividend withholding tax refund for foreign shareholders
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze Dutch Supreme Court decisions issued March 4 in Miljoen, X, and Société Général, concerning the calculation of dividend withholding tax refunds due portfolio investors . . .
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US IRS issues regulations on partnership allocations of creditable foreign tax expenditures
The IRS on Wednesday released final, temporary, and proposed regulations applicable to partnerships that claim the foreign tax credit for foreign income taxes. The regulations. effective February 4, clarify aspects of the section 1.704-1(b)(4)(viii) safe harbor rule that allows allocations of. . .
Featured News
EU Commission proposes measures to curb corporate tax avoidance
The European Commission today unveiled new tax proposals aimed at establishing a coordinated EU-wide approach to curb to multinational tax avoidance. The anti-tax avoidance package, or ATAP, includes a proposed directive for . . .
Europe
Asia-Pacific
Europe
Americas
Asia-Pacific
Czech Republic
Europe
Asia-Pacific
Americas
Americas
Europe
German tax law permitting loss carryforward following restructuring of failing companies is not State aid, EU court rules
Konstantin Sakuth of Linklaters LLP, Munich, discusses a June 28 European Court of Justice decision which settled a long-running debate regarding the legality under EU State aid rules of Germany’s “restructuring clause,” which allows carryback of tax losses following some company restructurings . . .
Americas
Asia-Pacific
Europe
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