Latest

The US IRS today issued guidance designed to give relief to US persons that own stock in certain foreign corporations. The new guidance was prompted by a need to address unintended consequences of the . . .

Europe

Italian Revenue clarifies new reporting option for patent box tax benefit

Gian Luca Nieddu, Head of Transfer Pricing and Tax Value Chain at Hager & Partners, Milan area, writes about Italy’s September 9 clarifications to the patent box regime . . .

Europe

Germany publishes revised tax law requiring disclosure of cross-border transactions

German tax practitioner Ninja-Antonia Reggelin notes that a draft German law, released September 27, requiring advisors or their clients to disclose information on cross-border transactions and structures to the national tax authorities differs from earlier versions . . .

Asia-Pacific

Turkey: new tax audit wave focuses on nonresident digital companies

Ramazan Biçer, a partner with Centrum, Istanbul, discusses a new wave of tax audits being undertaken in Turkey scrutinizing the taxation of nonresident taxpayers engaged in the digital economy . . .

Asia-Pacific

Australian tax office advises on transfer pricing for offshore drilling

September 27, 2019

The Australian Taxation Office (ATO) on . . .

Europe

Iceland joins BEPS MLI tax pact

September 27, 2019

Iceland on September 27 became a party to the . . .

Asia-Pacific

Hong Kong signs tax treaty with Estonia

September 26, 2019

The Hong Kong government today announced that Hong Kong and Estonia have signed a . . .

Europe

Jersey launches consultation on mandatory disclosure rules: Government of Jersey→

September 26, 2019

Asia-Pacific

Indian court rules Hitachi Singapore’s liaison office is a permanent establishment

September 26, 2019

Chartered Accountants Deepak Manoharan and Nathansha Dilip discuss the Hitachi case, a landmark ruling where the Delhi bench of the Income Tax Appellate Tribunal concludes that a liaison office could be treated as a permanent establishment of a foreign entity in India . . .

Europe

Denmark tax bill clarifies timing rules for transfer pricing documentation

September 25, 2019

Peter S. Andersen, a transfer pricing partner with Questro International, discusses Denmark’s proposed new requirements for transfer pricing documentation which were included in a Denmark Ministry of Taxation draft bill published on September 12 . . .

Multinational

OECD releases Tax Inspectors Without Borders annual report: OECD→

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Digital Economy

Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London

Arnas Laurynas, Managing Director of Quantera Global, London, discusses some of the highlights of IFA Congress 2019, held September 8–12 in London, which brought together leading international tax and transfer pricing experts from around the world . . .

Europe

Netherlands hits British American Tobacco with £902m (USD 1.1b) tax bill over fees paid for loans from UK holding company: DutchNews.nl→

Asia-Pacific

Japan, Uzbekistan agreed in principle to tax treaty

The governments of Japan and Uzbekistan have . . .

OECD publishes fact-sheet ahead of October report recommending higher taxes on polluting fuels: OECD→

Americas

Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico

Fernando Juarez Hernandez, an international tax attorney with Cacheaux, Cavazos & Newton, LLP, discusses Mexico 2020 tax reform, introduced September 8, which proposes far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code . . .

Asia-Pacific

India fires bazooka to lift economy, slashing corporate tax rates and enacting other tax relief

September 23, 2019

Rajesh Gandhi and Gaurav Chandak of Deloitte Haskins & Sells LLP, Mumbai, discuss the Indian government’s surprise announcement on Friday of a significant reduction in the corporate tax rates which became effective immediately . . .

Asia-Pacific

Philippines issues transfer pricing audit guidelines: EY→

September 19, 2019

Americas

Ireland outlines arguments in Apple state aid case: Ireland Department of Finance→

Digital Economy

Ireland will be better off with global tax deal, Saint-Amans says: Eoin Burke-Kennedy / The Irish Times→

Americas

France joins ICAP pilot to jointly assess MNE tax positions

France has joined the International Compliance Assurance . . .

Europe

EU finance ministers weighing changes to energy taxation

EU finance ministers at an informal ECOFIN meeting . . .

Europe

New Zealand, Guernsey sign tax treaty protocol

The governments of New Zealand and Guernsey have signed protocol to their tax information . . .

Americas

Japan, Uruguay sign tax treaty

The governments of Japan and Uruguay on September 13 signed their . . .

Europe

The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s 2020 budget and tax plan, presented September 17, which proposes modifications to the taxation of multinational firms . . .

Europe

Netherlands foreign investment fund tax regime may breach EU law, advocate general says

Jian-Cheng Ku and Rhys Bane of DLA Piper, Netherlands, discuss a September 5 opinion of the European Court of Justice Advocate General in a dispute involving the availability of Dutch dividend withholding tax refunds for foreign investment funds . . .

Asia-Pacific

India specifies transfer pricing arm’s length tolerance range

Gaurav Jain, a chartered accountant, and Priya Bhutani discuss Indian guidance released September 13 addressing the transfer pricing arm’s length tolerance range for wholesale trading and other activities . . .

Asia-Pacific

Australia updates guidance on simplified transfer pricing recordkeeping: Australian Taxation Office→

Europe

German finance minister endorses public country-by-country reporting of MNE tax information

German tax practitioner Ninja-Antonia Reggelin discusses the changing German position on public release of country-by-country reporting data . . .

Unresolved cross-border tax disputes continue to rise, OECD stats show

Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax . . .

Belgium

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian . . .

Europe

Google settles French tax dispute for €500m (USD 550m): BBC News→

Asia-Pacific

Vietnam to use legal, economic, technological means to collect tax from cross border services, official says: CustomsNews→

Americas

Ireland/Apple appeal of Commission’s 13 billion euro ($14.4 billion) State aid tax case to be heard this week in Europe’s General Court: Foo Yun Chee / Reuters→