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Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

Denmark

Denmark finance minister endorses global minimum tax for multinational groups, common tax base

March 4, 2019

Denmark’s ruling party, Venstre, supports the global adoption of a minimum tax on multinational group profits, Denmark’s finance minister said on March 3. The minister also . . .

Digital Economy

Germany studying 15 percent withholding tax on foreign online advertising revenue: Reuters→

February 19, 2019

Europe

EU Advocate General addresses deductibility of subsidiary losses in context of merger

January 28, 2019

Davide Anghileri of the University of Lausanne discusses the ECJ Advocate General’s January 10 opinion in the Memira Holding case which concerns the notion of final losses in the context of a merger . . .

Asia-Pacific

China to cut company tax and fees, reform VAT, finance minister says: Reuters→

January 22, 2019

Europe

Updated UK-Guernsey tax treaty enters into force

January 22, 2019

A new comprehensive tax treaty and protocol signed by the UK and Guernsey has entered into force, the UK . . .

First Look: EU investigating Netherlands tax rulings granted to Nike for state aid violations

January 10, 2019

The European Commission today announced that it has opened in-depth investigations into tax . . .

Asia-Pacific

Bangladesh tax authority’s transfer pricing unit begins operations: Jasim Uddin / New Age→

December 13, 2018

United States

US corps have repatriated fewer foreign profits than expected post-tax reform, blame foreign taxes: Laura Davison / Bloomberg→

December 7, 2018

The amount of offshore cash U.S. corporations have returned home so far this year . . .

More: ITEP, The Mercury News.

Algeria

Goldman Sachs and Cargill lose UK tax avoidance case involving Jersey company structure: Sophie Perryer / European CEO→

October 25, 2018

Europe

What Ireland’s finance bill means for multinational group taxation

October 23, 2018

Aisling Donohue a partner, with Andersen Tax, Dublin, analyzes the effect of Ireland’s October 18 finance bill on MNEs, focusing on changes to exit tax, CFC rules, income tax relief for investments, and tweaks to provisions on the amortization of intangibles . . .

Asia-Pacific

New Japan-Spain tax treaty signed

October 17, 2018

Japan and Spain have signed a new tax treaty, the . . .

Denmark

Denmark bill implementing EU ATAD proposes new rules for CFCs, interest, exit tax, GAAR, hybrids: EY→

October 4, 2018

Asia-Pacific

Cambodia changes transfer pricing rules for related party loans

September 23, 2018

Sujeet Karkala of Sciaroni & Associates discusses the Cambodia tax authority’s new transfer pricing instruction, issued August 21, which addresses the interest rates to be applied to related-party loans . . .

French minister proposes “sunset clause” for digital services tax at informal ECOFIN meeting: Luxembourg Times→

September 10, 2018

Europe

UK votes to remain outside EU VAT system after Brexit: Avalara VATLive→

July 18, 2018

Danish tax law denying cross-border loss relief is invalid, EU court rules

June 18, 2018

Davide Anghileri of the University of Lausanne discusses a June 12 decision of the EU Court of Justice which concludes that a Danish law that precludes the deductibility of final losses incurred by a foreign permanent establishment violates EU law . . .

Europe

Netherlands proposes temporary changes to tax consolidation regime to comply with EU law

June 13, 2018

Jian-Cheng Ku and Tim Mulder, DLA Piper, Amsterdam discuss a Netherlands Ministry of Finance legislative proposal published June 6 that contains emergency measures to bring the Dutch tax consolidation regime in line with EU law . . .

Europe

Ireland sets out plan to exchange info with other EU States on private tax rulings signed with multinationals

May 7, 2018

Irish Revenue, on May 7, updated its tax guidance to include its plan to implement an EU directive requiring governments to automatically exchange information with other EU States about the private cross-border tax rulings and advance pricing agreements they sign with multinational . . .

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Americas

US IRS to amend country-by-country reporting regulations to protect national security

March 30, 2018

The US IRS today announced that it will amend its guidance for large multinationals on country-by-country reporting obligations to prevent reporting that jeopardizes national . . .

Europe

Irish tax authority clarifies transfer pricing rules for low-value intra-group services

March 19, 2018

Irish Revenue on March 15 provided new guidance taxpayers on Ireland’s simplified transfer pricing approach to low-value intra-group . . .

Europe

Ireland updates tax rules on capital allowances for intangible assets

February 5, 2018

Irish Tax and Customs on February 2 updated its tax and duty manual to reflect changes made in Finance Act 2017 that limit capital allowances for intangible assets plus deductions for related . . .

Europe

Commission publishes opening decision in Huhtamäki state aid probe

May 7, 2019

The EU Commission on May 3 published . . .

Asia-Pacific

Proposed India profit attribution rules reject OECD approach, add “sales” and “users” as apportionment factors

April 24, 2019

Madhan N of PricewaterhouseCoopers Private Limited, India, discusses the Indian government’s controversial proposal for new rules for attributing profits to Indian permanent establishments . . .

UN tax committee releases draft transfer pricing chapter on financial transactions, other docs ahead of meeting (Updated)

April 10, 2019

The UN has released draft updates to the United Nations Practical Manual on Transfer Pricing for Developing Countries — including a key chapter on financial transactions — and more . . .

Americas

US advance pricing agreement applications surged in 2018, data shows

March 27, 2019

The US IRS today issued its annual report providing statistics on its advance pricing agreement (APA) program. The data reveals a . . .

Asia-Pacific

Hong Kong extends CbCR deadline

March 25, 2019

The Hong Kong government has extended the deadline for Hong Kong entities . . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Europe

EU Advocate General clarifies when sub-subsidiary losses are final for tax deduction

January 18, 2019

Davide Anghileri of the University of Lausanne discusses the EU Advocate General’s January 10 opinion in the Holmen case . . .

Americas

Facebook’s trial in $5 billion US transfer pricing dispute extended to Feb. 2020: Sony Kassam / Bloomberg Tax→

January 4, 2019

Europe

Romania finance minister proposes tax on bank assets at a rate based on interbank ROBOR interest rates, (expected levy would be .9 % from Jan. 2019): Sorin Melenciuc / Business Review→

December 19, 2018

The Romanian government follows in . . .

More: Bloomberg, Reuters, See News.

Switzerland to end special tax allocation practices for new principal companies, finance branches

November 27, 2018

The Swiss government on November 14 announced that it will end special taxpayer-favorable allocation rules for new principal companies and Swiss finance branches, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, . . .

Americas

US Treasury Secretary Mnuchin decries “unilateral and unfair” digital tax proposals

October 25, 2018

US Treasury Secretary Steven Mnuchin today issued a statement condemning proposals being floated in the EU and elsewhere . . .

Americas

Despite US tax reform, companies still moving IP abroad: Laura Davison / Bloomberg→

October 16, 2018

EU Commission’s digital services tax lacks legal basis because it is not an indirect tax, Council paper says: Financial Times / Mehreen Khan→

October 11, 2018

Asia-Pacific

Israeli transfer pricing guidance addresses low-interest loans

October 4, 2018

Jacky Houlie and Shlomo Hubscher of JH & Co. Law Office, Tel Aviv-Yafo, Israel, discuss a new circular produced by the Israeli tax authorities addressing transfer pricing aspects of low-interest domestic loans . . .

Asia-Pacific

New Zealand government report advocates no reduction in corporate rates, consideration of digital firm equalization levy: Tax Working Group→

September 23, 2018

Africa

South African Revenue to revive large business unit

August 24, 2018

The South African Revenue Service (SARS) today announced it will revive its . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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