Asia-Pacific
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Europe
Transfer pricing in Poland – a `Runmageddon’ for tax compliance teams
Milena Kaniewska-Srodecka, CrossBorder Solutions, discusses the rapidly evolving transfer pricing landscape in Poland, which is now quite challenging for compliance teams to navigate; even as the tax law in this area seems to be becoming more simplified on the one hand, there are still areas of dispute on the other, some unexpected obstacles, and the increasing consequences for noncompliance.
Americas
Implications of US Sixth Circuit Court’s reaffirmation that Whirlpool must pay taxes on US $45 million in income
Jack Taylor, University of Minho, discusses the long-term implications of the U.S. Court of Appeals for the Sixth Circuit’s March 2 reaffirmation of the previous December 2021 decision in Whirlpool v. Commissioner of Internal Revenue, which held that Whirpool must pay taxes on USD 45 million in income.
Americas
Europe
Africa
Europe
Electricité de France v. France: pricing of intercompany convertible and vanilla debt
New York City Economist Dr. J. Harold McClure analyzes the French Court of Appeal’s January 25 ruling in favor of the multinational in a somewhat involved intercompany financing pricing issue in a decision in case number 20VE00792; SAS Electricité de France International (SAS EDFI) is France’s largest electricity provider and owns the UK affiliate EDF Energy UK Ltd (EDFE).
G20
Asia-Pacific
Belarus
Europe
The EU maze for deducting final losses of a nonresident permanent establishment
Dragos Dancau, Ericsson, discusses the European Court of Justice’s March 10 publication of the opinion of Advocate General Collins in C-538/20 Finanzamt B v W AG; the case leaves questions the German referring court raised on how previous cases should be interpreted and shows the maze in analyzing the deduction of the final losses of a nonresident PE within the EU.
Asia-Pacific
Accounting
Europe
Europe
Switzerland likely to change its constitution because of Pillar Two global minimum tax plan
Peter Hongler, University of St. Gallen, predicts Switzerland will likely change its constitution because of Pillar Two—a proposal to address global profit shifting by imposing a global minimum tax of at least 15%—and took its first step in that direction by opening a public consultation on the OECD/G20 minimum tax plan for multinationals on March 13.
Estonia
Europe
Europe
Asia-Pacific
Europe
The Advocate General’s opinion in the Fiat appeal: a plea for legal certainty
Leopoldo Parada, University of Leeds School of Law, analyzes the three grounds of appeal in the Fiat Chrysler Finance Europe v Commission case and warns that if the European Court of Justice agrees to follow the Advocate General’s opinion, there may be important ramifications that go beyond this transfer pricing case.
Denmark
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G20
Americas
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Americas
Americas
The Pillar Two model rules: a train wreck in the making
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
Digital Economy
Africa
Accounting
Europe
Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract
Pilar Barriguete and Victoria Arozamena, Kroll Advisory, S.L., discuss Spain’s recent tendency to challenge intragroup services, denying its corporate income tax deductibility; this view is most recently reflected in the Spanish National Court’s January 25 ruling that it did not consider the provision of intragroup services to be sufficiently proven in the absence of a written contract.
Denmark
Danish High Court rules on the application of EU Arbitration Convention and MAP in transfer pricing case
Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a recent transfer pricing ruling from the High Court of Eastern Denmark in a case on the application of the EU Arbitration Convention and mutual agreement procedures; this ruling is an indication that settling disputes by arbitration is an outcome that will become ever more important in the future of Danish tax law.
Americas
Mexican tax reform 2022 – key topics to review from an international fiscal perspective
Arturo Treviño Villarreal, Fratelli Consultores, discusses several changes to Mexico’s 2022 tax reform that are having significant implications for both domestic taxpayers and nonresidents, triggering an array of tax reporting and compliance obligations that could impact cross-border transactions of MNEs operating in the country.
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Americas
Americas
Americas
Americas
Africa
