Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses a recent Italian Supreme Court decision addressing whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes where the court applied the European Court of Justice’s holdings in the so-called Danish cases . . .
Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .
Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses guidance issued August 6 by Poland’s Minister of Finance that addresses whether a dividend payment among associated companies falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. . . .
Dr. Harold McClure, a New York City economist, notes the Korean National Tax Service’s August 27 announcement that it is investigating the transfer pricing practices of 21 multinationals, including US technology and media multinational, Netflix, and considers what the tax service’s transfer pricing dispute with Netflix might be. . .
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