Latest

Europe

NGO report reveals German pharma company Qiagen’s tax avoidance through intercompany loans: SOMO→

Europe

Russia, Malta signed protocol to tax agreement raising withholding tax on dividends and interest to 15 percent: TASS→

Europe

EU Commission publishes VAT e-commerce explanatory guidance:→

Americas

US IRS advises taxpayers to exit abusive micro-captive insurance schemes, will target variations of abuse identified in Notice 2016-66: IRS→

October 1, 2020

Africa

African tax administrators release model digital services tax legislation, say global tax deal unlikely this year

October 1, 2020

The African Tax Administration Forum (ATAF), comprised of tax administrations from 38 African countries, on September 30, published sample digital . . .

Americas

California governor vetoes bill requiring the Franchise Tax Board to disclose to the legislature of large corps’ gross receipts, tax liabilities, tax credits: Chirs Micheli / California Globe→

October 1, 2020

Europe

Dutch opposition party proposes controversial dividend exit tax

Jian-Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, DLA Piper, Amsterdam, discuss a Dutch proposal to introduce an exit tax to the dividend withholding tax which, if enacted, would apply to Dutch resident companies undertaking cross-border reorganizations as of September 18 . . .

Americas

US issues final regs on gain or loss of foreign persons from sale or exchange of partnership interests [TD 9919]: US Treasury→

Americas

US issues tax regs on source of income from certain sales of personal property including inventory by nonresidents attributable to a US fixed place of business [TD 9921]: US Treasury→

Americas

US issues proposed foreign tax credit regs [REG-101657-20]: US Treasury→

Americas

US issues final and temporary foreign tax credit regs [TD 9922]: US Treasury→

Europe

UK affiliate of Airbnb UK hit with £1.8 million (USD 2.3 million) tax bill for 2019 after audit: Reuters→

Asia-Pacific

Jordan becomes 53rd country to deposit instrument of ratification for BEPS MLI: OECD→

Americas

US corrects FDII and GILTI regs: Federal Register→

Africa

Botswana, Eswatini, Jordan, and Namibia sign Multilateral Convention on Mutual Administrative Assistance in Tax Matters: OECD→

Multinational

Tax Inspectors Without Borders activities described in new report: OECD/UNDP→

Digital Economy

EU publishes explanatory notes on VAT e-commerce rules: European Commission→

Denmark

Spain must recover illegal state aid for tax lease schemes

Susi Baerentzen, Ph.D., Copenhagen, Denmark, discusses the General Court of the European Union’s September 23 ruling in the Spanish tax leasing case, aka the Lico Leasing case, a long-running taxation state aid dispute that had been referred back from the European Court of Justice in 2018 . . .

Europe

EU to propose system for harmonized withholding tax relief

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a tax proposal included in the EU Commission’s September 24 Capital Markets Union Action Plan . . . .

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

Europe

The 2021 Dutch tax plan: key takeaways for multinational enterprises

September 28, 2020

Jian-Cheng Ku, Tim Mulder, and Xander Stubenrouch of DLA Piper, Amsterdam, discuss the Dutch government’s September 15 tax legislative proposals, focusing on the items most relevant to multinational enterprises . . .

Americas

Peru and Japan: the road to a double tax treaty

September 28, 2020

Franz Salazar Anccasi, Tax Advisory Manager at Edwards Peru, Lima, Peru, discusses the status of a tax treaty being negotiated by Japan and Peru . . .

Americas

OECD, Brazil tax officials provide update of transfer pricing alignment project

September 28, 2020

Francisco Lisboa Moreira a tax partner at Bocater Advogados, São Paulo, Brazil, discusses a recent conference where senior OECD and Brazil tax officials provided an update on efforts to align Brazil’s transfer pricing laws with global standards . . . .

Europe

EU Commission appeals Apple State aid ruling

The European Commission today announced that it has appealed the EU General Court’s ruling in the Apple State aid case to . . .

Americas

US IRS corrects final regs on limitations dividends received deduction: Federal Register→

Americas

Panama introduces EMMA tax regime to attract multinational manufacturers

Laura Pinilla, an associate at BaseFirma Colombia, discusses new Panama tax incentives for multinationals signed into law on August 31 . . .

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Europe

Poland provides more details on plan to require large firms to publicize tax strategy

September 24, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses a September 16 bill published by the Polish government requiring large corporations to prepare and publish a report on the execution of their tax strategy each fiscal year . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Europe

UK Autumn 2020 Budget canceled: London Evening Standard→

Europe

Ireland proposes revisions to investment limited partnership structure: Ireland Department of Finance→

Americas

US IRS issues proposed regs that modify the ownership attribution rules applicable to outbound transfers of stock or securities of a domestic corporation under section 367(a): Federal Register→

Americas

US IRS publishes final regs on ownership attribution for determining CFC or US shareholder status: Federal Register→