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Europe

UK Treasury minister defends Google tax settlement

January 25, 2016

UK Treasury Secretary David Gauke today defended an HM Revenue and Customs settlement with Google relating to back taxes, telling Members of Parliament that the company . . .

Multinational

Profs argue that BEPS concerns better addressed if passive income taxed at source, active income taxed at residence, Reuven S. Avi-Yonah & Haiyan Xu / SSRN→

January 19, 2016

See: Why BEPS and MAATM are Inadequate Responses, and What Can Be Done About It, by Reuven S Avi-Yonah and Haiyan Xu. Available at: SSRN.

Europe

Luxembourg law adapting corporate tax code to EU law contains gaps

January 15, 2016

Paloma Schwarz Martínez, a PhD Researcher at the University of Luxembourg, analyzes Luxembourg’s new law implementing changes made to the EU Parent-Subsidiary directive, noting that restrictions on hybrid mismatch arrangements and new antiabuse rules will not apply when non-EU companies are involved in a transaction.

Europe

UK CFC law partially granted state aid, EU Commission says

April 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the European Commission on April 2 has announced that is has found that the UK controlled foreign company legislation’s group financing exemption is partially illegal because it grants state aid . . .

Asia-Pacific

Australia puts digital tax on hold: Daily Mail→

March 21, 2019

Multinational

Tax advisory work grew by 8.6% globally in 2017 hitting record GBP 15.4bn (USD 20.2bn): Economia→

January 30, 2019

UN tax committee to update to key transfer pricing manual for developing countries

January 22, 2019

The next edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries will include a new chapter on financial transactions, substantial . . .

Switzerland updates AEOI list

December 17, 2018

The Swiss Federal Tax Administration has updated its list of the partner jurisdictions with which Switzerland is implementing automatic exchange of financial account Information writes Davide Anghileri, University of Lausanne . . .

Americas

US says South Korea proposal requiring tech companies to set up servers and thus create PE there violates trade agreement: Lee Kyung-min / The Korea Times→

December 11, 2018

Cabo Verde

Cabo Verde joins “Inclusive Framework on BEPS” to fight tax avoidance by multinationals

November 28, 2018

Cabo Verde has joined the “Inclusive Framework on BEPS,” a coalition of countries . . .

Europe

Draft Brexit deal requires UK to observe “level playing field” in tax and state aid; adopt EU code of conduct, tax information exchange, investment firm reporting: Jon Henley / The Guardian→

November 14, 2018

Europe

Ireland seeks public feedback on proposed hybrid, interest deduction tax rules

November 14, 2018

Ireland’s government on November 14 launched a public consultation on proposed changes . . .

France, Germany advance compromise for EU-wide digital services tax

November 6, 2018

Germany and France which, along with Italy and Spain, first floated the idea of temporary EU-wide digital services tax, have offered a revised proposal in . . .

Europe

Netherlands reverses plan to abolish dividend withholding tax, offers new proposals to attract MNEs

October 23, 2018

Tim Mulder and Robin Theuns of DLA Piper Nederland N.V., discuss the Dutch government’s latest proposal, announced October 15, to scrap its earlier plan to abolish the dividend withholding tax and add new tax rules encouraging investment . . .

Americas

US, Israel establish task force to recommend amendments to tax treaty: CTech→

October 23, 2018

Americas

US Senate confirms Charles Rettig as IRS commissioner

September 13, 2018

The US Senate on Wednesday confirmed Charles Rettig as . . .

Poland “innovation box” would reduce tax rate for IP income to 5 percent

September 5, 2018

Monika Laskowska of PwC Poland discusses a draft Polish tax law, presented August 24, that would reduce the tax rate on income derived from qualified intellectual property rights . . .

Asia-Pacific

India should not be the only country funding UN international tax committee, ministry consultant argues: Abdul Muheet Chowdhary / The Wire→

August 30, 2018

Africa

South Africa publishes tax treaty mutual agreement procedure guide

July 30, 2018

The South African government on July 25 published a new guide on accessing the mutual agreement procedure (MAP), which is a process benefiting taxpayers that conduct cross-border business agreed to by South. . .

Europe

Spain considers 15 percent corporate minimum tax, reduced deductions: Brett Allan King / Bloomberg Tax→

July 25, 2018

Estonia

UK ratifies, Estonia signs OECD multilateral instrument on tax avoidance

July 2, 2018

The OECD announced June 29 that the UK has ratified and Estonia has signed a multilateral tax treaty designed to curtail tax avoidance by multinational . . .

Europe

Ireland updates guidance on transfer pricing compliance

May 30, 2018

Irish Tax and Customs on May 28 updated Tax and Duty Manual Part 35A-01-01, setting out the government’s approach to monitoring compliance . . .

Multinational

Professors advocate replacing corporate tax on MNE profits with dividend and consumption tax: Nicolai J. Foss, Ram Mudambi, Samuele Murtinu / SSRN→

May 23, 2018

Europe

Why France’s appellate court concluded that ValueClick’s French subsidiary did not have a PE in France

April 9, 2018

Terence Wilhelm, managing partner of CARA Avocats, Lyon area, France, discusses key takeaways from the Paris Administrative Appeal Court’s recent decision in ValueClick, where the court adopted a restrictive view of the concept of permanent establishment applying the applicable French tax treaty based on the old OECD model . . .

Asia-Pacific

Hong Kong and India sign comprehensive tax agreement

March 20, 2018

The governments of Hong Kong and India signed a comprehensive tax agreement on March 19, Hong Kong’s government . . .

OECD model tax treaty shouldn’t guide EU law on beneficial ownership, Advocate General says

March 7, 2018

The EU Advocate General of the Court of Justice of the European Union, Juliane Kokott, on March 1, released her opinion in four cases dealing with the interpretation of the beneficial ownership concept where the Interest Royalty Directive applies and in two cases where the Parent-Subsidiary Directive applies, writes Davide Anghileri of the University of Lausanne . . .

Europe

France favors lower tax rate on digital firm revenue to speed implementation, Finance Minister says: Reuters→

March 5, 2018

EU Commission to propose 1–5 percent tax on digital firm revenues, leaked documents say: Francesco Guarascio/ Reuters→

February 26, 2018

Europe

Italy issues comprehensive regulations detailing new patent box regime

February 13, 2018

MNE Tax contributing editor Davide Anghileri discusses regulations published February 6 that implement Italy’s patent box regime. . . .

Asia-Pacific

Australia releases more guidance on diverted profits tax

February 7, 2018

The Australian Taxation Office (ATO) today released more draft guidance on its new diverted profits tax on large multinationals . . .

Americas

US IRS issues more tax guidance on deemed repatriation of offshore earnings

January 19, 2018

The US IRS today issued an advance copy of Notice 2018-13, providing guidance on the transition tax on foreign earnings of foreign subsidiaries of US companies called for under the newly enacted Tax Cuts and Jobs Act. The notice, to be . . .

Americas

Luxembourg to feel impact of US tax reform: Keith O’Donnell / Delano→

December 26, 2017

Multinational

Adjusted cost of goods sold as a proxy for related party purchases in transfer pricing

November 14, 2017

Ednaldo Silva, Ph.D., founder and managing director at RoyaltyStat, discusses how adjusting cost of goods sold to remove the effect of one-year change in inventories is important to determine the arm’s length gross profits of intercompany (related party) inventory goods transactions. . . .

Americas

US IRS’s latest priority guidance business plan includes several new international tax projects: US Treasury→

October 26, 2017

Americas

US, Luxembourg agree to exchange country-by-country reports on multinational groups for tax purposes

October 24, 2017

US Treasury has today announced the signing of an agreement with Luxembourg to exchange country-by-country reports on the tax affairs of multinational groups operating . . .

Switzerland advances tax law on country-by-country reporting for multinationals

September 29, 2017

Davide Anghileri of the University of Lausanne reports that Swtitzerland’s Federal Council adopted an ordinance on the international automatic exchange of country-by-country reports on multinational firms during its meeting on 29 September.

Africa

China, Kenya sign tax treaty

September 25, 2017

China and Kenya signed a new tax treaty on September 21, China’s official press agency, Xinhua, has reported. The tax treaty was negotiated . . .

Europe

EU Commission sues France to enforce Accor decision on intercompany dividend taxation

September 5, 2017

The EU Commission has brought an action in the Court of Justice of the European Union, alleging that France is not complying with the Court’s decision in Accor concerning France’s application of the dividend tax credit to intercompany . . .

Asia-Pacific

India hits Hutchison with Rs 32,320 crore (USD 4.8 billion) tax bill in ongoing Vodafone dispute: The Economic Times→

September 1, 2017

Source: Vodafone: Income Tax department seeks Rs 32,320 crore from Hutchison over Vodafone deal – The Economic Times

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

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