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Report details UN Committee of Experts’ fourteenth session on international tax
An official report describing the outcome of the fourteenth session of the UN’s Committee of Experts on International Cooperation in Tax Matters (Committee of Experts) was released on the UN website this week. The fourteenth session . . .
Europe
France’s additional tax on dividends is contrary to law, EU court concludes
The European Court of Justice in May 17 decision ruled that France’s additional tax on dividends is not compatible with article 4 of the parent-subsidiary directive, writes Davide Anghileri of the University of Lausanne . . .
Americas
Kautter formally nominated as US assistant secretary for Tax Policy
David J. Kautter has been nominated to serve as an US Assistant Secretary of the Treasury for Tax Policy, according. . .
Americas
Africa
Mauritius signs tax treaties with Ghana, Jersey, negotiating Mali treaty
The Mauritius Revenue Authority has advised that Mauritius has signed tax treaties . . .
Europe
Asia-Pacific
Indian POEM – not so poetic! An analysis of India’s new place of effective management rules
Ashish Sodhani and Ameya Mithe of Nishith Desai Associates provide a comprehensive analysis of India’s new guidelines for determining a foreign company’s place of effective management . . .
Europe
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
Asia-Pacific
Europe
France’s denial of dividend withholding tax exemption under EU scrutiny
The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri of the University of Lausanne . . .
Europe
EU Commission releases opening decision in State aid probe of Luxembourg tax rulings granted Engie
The European Commission today published a non-confidential version of its decision to open a State aid investigation into whether a tax rulings granted by Luxembourg to Engie, formally known as GDF Suez . . .
Americas
Starbucks files suit challenging Commission’s decision on State aid in tax case
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission’s decision of October 21, 2015, which concluded that an advance pricing agreement . . .
Asia-Pacific
Australian guidance defines “Australian consumer” for cross-border VAT rules
The Australian Taxation Office, on December 22, published a draft goods and services ruling (GSTR 2016/D1) discussing the meaning of “Australian Consumer” for purposes of rules that . . .
Americas
Macao and US sign Model 2 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Macao and the US have signed a Model 2 intergovernmental . . .
Americas
Switzerland agrees to automatic exchange of information with Brazil, Mexico, Uruguay
Davide Anghileri of the University of Lausanne discusses Switzerland’s November 18 signing of joint declarations on the introduction of automatic exchange of information in tax matters with Brazil, Mexico, and Uruguay
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Europe
Argentina, Switzerland agree to automatically exchange financial account information for tax purposes
Davide Anghileri of the University of Lausanne discusses the November 16 signing by Switzerland and Argentina of a joint declaration on the introduction of automatic exchange of information in tax matters . . .
Africa
BRICS: tax policies should enhance growth, address BEPS
BRICS leaders, following their summit held October 15–16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
Americas
Final earnings stripping regulations released
The US Treasury Department on Thursday released final earnings stripping regulations under section 385, resisting calls by business and Republican lawmakers to slow down . . .
Asia-Pacific
Europe
Switzerland’s Canton of Zug to offer 12 percent corporate tax rate, patent box, R&D break
Swiss tax expert Davide Anghileri discusses the cantonal government of Zug’s September 19 announcements outlining corporate tax reform III, designed to create a tax environment that maintains the canton as an attractive place to invest but also bring it in-line with international tax standards . . .
Asia-Pacific
Kuwait signs tax transparency agreement
The OECD has announced that Kuwait has signed the CRS Multilateral Competent Authority Agreement, a step required to put into place automatic exchange of financial account information with . . .
Americas
Americas
Business reps urge overhaul of US debt/equity proposed regulations at hearing
Sam Olchyk and Arthur Norman of Venable LLP, Washington, report on a July 14 IRS hearing on controversial proposed section 385 earnings stripping regulations, noting that the speakers advanced a number of compelling arguments in favor of modifying the tax regulations, but IRS and Treasury officials remained mostly silent, not revealing their plans regarding the regulations . . .
Algeria
Austria
Multinational
Tax officials selected to chair OECD global forum and peer review group
Maria José Garde has been appointed as the new chair of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes and Huey Min Chia-Tern has taken over as chair of the . . .
Europe
German Federal Assembly wary of public release of country-by-country transfer pricing reports on multinationals
Tax specialist, Ninja-Antonia Reggelin, discusses the state of play in Germany regarding a Commission proposal for public release of country-by-country reports on multinationals . . .
Americas
China, India, Canada, Iceland, Israel, New Zealand agree to exchange of country-by-country transfer pricing reports
Officials from six countries today signed a multilateral agreement that sets out the parameters for the automatic exchange of country-by-country reports on large multinational corporations. China, India, Canada, Iceland, Israel, and New Zealand joined 33 other countries that have . . .
Americas
Americas
US and Vietnam sign Model 1 FATCA IGA, agreement not treated as “in effect”
The US Treasury Department updated its FATCA website on April 19, reporting that Vietnam has signed a Model 1 intergovernmental agreement (IGA) with the. . .
Asia-Pacific
UAE signs tax treaty with United Kingdom
The United Arab Emirates and the United Kingdom signed a tax treaty . . .
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OECD releases electronic format for exchange of BEPS country-by-country tax reports
The OECD on Tuesday released a standardized electronic format for the exchange between tax administrations of country-by-country (CbC) reports about multinational . . .
Asia-Pacific
Europe
Luxembourg announces corporate tax rate cut
Luxembourg is planning to lower its corporate tax rate over the next two years, writes Paloma Schwarz Martínez, a PhD researcher at the University of Luxembourg. . . .
Americas
US tax regulations extend foreign financial asset reporting to domestic entities
Michael J. Miller of Roberts & Holland, New York, reviews final US regulations, released February 23, that require domestic corporations, partnerships, and trusts to report their foreign financial assets to the IRS . . .
