Latest

Americas

Curaçao publishes country-by-country reporting guidance: Curaçao Finance Minstry→

April 9, 2019

Tax officials from 46 countries agree to expand ICAP pilot, improve transfer pricing administration

March 29, 2019

TThe OECD Forum on Tax Administration on March 29 announced their support for . . .

Vodafone voluntarily publishes country-by-country report: Vodafone→

March 25, 2019

Multinational

To end profit shifting, MNEs should be taxed in location of sale, UC Berkeley prof. argues: Gabriel Zucman / Economists for Inclusive Prosperity→

February 26, 2019

OECD report shows countries’ progress shutting down tax treaty shopping

February 14, 2019

The OECD today released a report assessing whether 116 countries are following . . .

Americas

US IRS issues final regulations on section 965 repatriation tax

January 18, 2019

The US IRS on January 15 published final regulations under section 965, which provides for a one-time transition . . .

Americas

Mark Madrian joins Valentiam Group’s US West Coast transfer pricing practice

January 9, 2019

Valentiam Group, a recently formed US transfer pricing and valuation firm, today announced that . . .

EU proposes detailed VAT rules for cross-border e-commerce

December 13, 2018

MNE Tax contributing editor, Davide Anghileri, writes that the EU Commission has proposed detailed measures designed to enable a smooth transition to new EU value-added tax (VAT) rules for e-commerce slated to come into force January 2021 . . .

Asia-Pacific

Qatar signs BEPS MLI aimed at fighting tax avoidance by multinationals

December 4, 2018

Qatar today signed a multilateral tax treaty designed to stop tax avoidance techniques used . . .

Europe

UK transfer pricing rules apply to capital transactions such as issuing shares, court finds

October 10, 2018

Liz Hughes, a partner with Grant Thornton UK LLP, discusses an October 2 decision of the UK Upper Tribunal which concludes that a share transaction is within the scope of the transfer pricing rules and addresses the meaning of “losses” for purposes of the derivatives tax code . . .

Europe

French budget 2019 unveiled

September 26, 2018

The French government on Monday unveiled its 2019 budget, providing significant tax relief for business. MNE Tax will publish an expert analysis of the new budget shortly. . .

Americas

Sweeping Chile tax reform plan proposes tax on digital services, restores corporate tax integration

September 18, 2018

Francisco Sepúlveda of RGS Abogados discusses the Chilean government’s proposed tax reform plan, presented August 23, which would reestablish full corporate tax integration, introduce new permanent establishment definitions, weaken the GAAR, enhance deductible business expenses, and impose a new withholding tax on digital services to be collected by credit card companies, among other measures . . .

Americas

Tax lawyer Robert J. Kovacev joins Norton Rose Fulbright

September 12, 2018

Robert J. Kovacev has joined Norton Rose Fulbright as a partner in its Washington, DC and San Francisco offices; the firm announced . . .

Americas

Tax reform’s BEAT hits US MNE’s Bermuda reinsurance affiliates driving M&A activity: Bethan Moorcraft / Insurance Business→

September 10, 2018

United States

Lobby groups attack and defend US treatment of reinsurance under BEAT: Ezequiel Minaya & Nina Trentmann / WSJ→

August 22, 2018

Americas

US IRS issues final tax regulations addressing inversions

July 13, 2018

The US IRS on the Department of the Treasury on July 12 issued final tax regulations addressing . . .

Americas

US Supreme Court overturns Quill precedent: what it means for retailers

June 21, 2018

Michael Bernard and Nancy Manzano of Vertex Inc. discuss today’s US Supreme Court’s decision in Wayfair, which overturned the 1992 Quill v. North Dakota ruling and changed the physical presence requirements for sales and use tax collection for online sellers, out-of-state merchants, and global companies selling to US-based customers . . .

Luxembourg private tax rulings granted French utility Engie are illegal State aid, EU Commission concludes

June 20, 2018

The European Commission has determined that private tax rulings granted by Luxembourg to subsidiaries of Engie, a French energy company, concerning the tax treatment of intercompany zero interest rate –

Saint-Amans clarifies plan for OCED work on digital economy taxation

June 10, 2018

Speaking at the 2018 OECD International Tax Conference, held June 4–5 in Washington, Pascal Saint-Amans, Director, Centre for Tax Policy and Administration sought to clear up confusion regarding the timing of an OECD-led effort to achieve consensus among countries. . .

Americas

US’s FDII export subsidy may be immune to international challenge but bad tax policy, professor says: Chris William Sanchirico / SSRN→

May 23, 2018

Asia-Pacific

eBay’s Israel subsidiary to challenge in court 156 million shekel (USD 43.5 million) tax bill: Eliran Rubin & Efrat Neuman / Haaretz→

April 28, 2018

Asia-Pacific

India proposes tweak to APA application to enable BEPS-mandated exchange of information on tax rulings: Financial Express→

April 12, 2018

VW’s Luxembourg tax ruling may be next subject of EU State aid probe: Stephanie Bodoni / Bloomberg→

March 27, 2018

Europe

Poland is fourth country to ratify BEPS multilateral instrument on tax avoidance

March 8, 2018

oland has become the fourth country to ratify the BEPS multilateral instrument, the OECD has announced on its website. Thus, only one more country must ratify . . .

Asia-Pacific

Korea considers tax audit challenging low prices GM charged affiliate for autos: Kim Bo-gyung / The Korea Herald→

March 2, 2018

EU Parliament to launch TAXE 3, probing tax evasion and avoidance

February 9, 2018

The European Parliament on February 7 voted to launch another investigation into financial crimes, tax evasion, and tax avoidance, tentatively named TAXE 3. According to the . . .

Americas

US tax reform’s implications for IP: Michael Rosen / AIE→

February 1, 2018

Asia-Pacific

Australia 2017 year-in-review: tax authority takes aim at large multinational business

January 7, 2018

Zara Ritchie and Natalya Marenina of BDO take a look back at the most significant Australian international tax developments of 2017 — including the new focus on significant global entities, transfer pricing documentation, diverted profits tax, and cross-boarder financing — and consider what 2018 is likely to bring . . .

Americas

US agrees to exchange country-by-country tax reports with Spain, announces effective dates of Malta and Guernsey agreements

December 21, 2017

The US has signed a competent authority agreement with Spain to exchange country-by-country tax reports on multinational firms, the IRS announced December 20. The IRS also announced the effective dates of competent authority agreements signed with Malta and Guernsey. All three . . .

Europe

Facebook to end practice of booking all non-US advertising revenue in Ireland

December 12, 2017

Facebook today announced that it will stop booking some of its non-US advertising revenue in Ireland and instead pay tax in the country where sales are made. The move will apply to all countries in which Facebook currently has an office . . .

EU officials say US tax reform measures could violate international agreements: Joe Kirwin / Bloomberg BNA→

December 6, 2017

Americas

US Senate and House tax bill differences to be resolved by conference committee: Steptoe & Johnson→

December 5, 2017

Asia-Pacific

New Zealand announces tax working group, appoints chair

November 24, 2017

New Zealand Finance Minister Grant Robertson and Revenue Minister Stuart Nash today announced the establishment of a tax working group to recommend changes to the tax system to improve the fairness of the system . . .

Europe

Spanish firm Euskaltax joins Andersen Global

November 16, 2017

Andersen Global, an international association of legally separate, independent member firms, on November 13, announced that it has entered into a collaboration . . .

Europe

Americas

Prof proposes “Dual Business Enterprise Income Tax” for US corporate reform: Edward D. Kleinbard / SSRN→

August 31, 2017

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

Curaçao publishes country-by-country reporting guidance: Curaçao Finance Minstry→

Tax officials from 46 countries agree to expand ICAP pilot, improve transfer pricing administration

Vodafone voluntarily publishes country-by-country report: Vodafone→

To end profit shifting, MNEs should be taxed in location of sale, UC Berkeley prof. argues: Gabriel Zucman / Economists for Inclusive Prosperity→

OECD report shows countries’ progress shutting down tax treaty shopping

US IRS issues final regulations on section 965 repatriation tax

Mark Madrian joins Valentiam Group’s US West Coast transfer pricing practice

EU proposes detailed VAT rules for cross-border e-commerce

Qatar signs BEPS MLI aimed at fighting tax avoidance by multinationals

UK transfer pricing rules apply to capital transactions such as issuing shares, court finds

French budget 2019 unveiled

Sweeping Chile tax reform plan proposes tax on digital services, restores corporate tax integration

Tax lawyer Robert J. Kovacev joins Norton Rose Fulbright

Tax reform’s BEAT hits US MNE’s Bermuda reinsurance affiliates driving M&A activity: Bethan Moorcraft / Insurance Business→

Lobby groups attack and defend US treatment of reinsurance under BEAT: Ezequiel Minaya & Nina Trentmann / WSJ→

US IRS issues final tax regulations addressing inversions

US Supreme Court overturns Quill precedent: what it means for retailers

Luxembourg private tax rulings granted French utility Engie are illegal State aid, EU Commission concludes

Saint-Amans clarifies plan for OCED work on digital economy taxation

US’s FDII export subsidy may be immune to international challenge but bad tax policy, professor says: Chris William Sanchirico / SSRN→

eBay’s Israel subsidiary to challenge in court 156 million shekel (USD 43.5 million) tax bill: Eliran Rubin & Efrat Neuman / Haaretz→

India proposes tweak to APA application to enable BEPS-mandated exchange of information on tax rulings: Financial Express→

VW’s Luxembourg tax ruling may be next subject of EU State aid probe: Stephanie Bodoni / Bloomberg→

Poland is fourth country to ratify BEPS multilateral instrument on tax avoidance

Korea considers tax audit challenging low prices GM charged affiliate for autos: Kim Bo-gyung / The Korea Herald→

EU Parliament to launch TAXE 3, probing tax evasion and avoidance

US tax reform’s implications for IP: Michael Rosen / AIE→

Australia 2017 year-in-review: tax authority takes aim at large multinational business

US agrees to exchange country-by-country tax reports with Spain, announces effective dates of Malta and Guernsey agreements

Facebook to end practice of booking all non-US advertising revenue in Ireland

EU officials say US tax reform measures could violate international agreements: Joe Kirwin / Bloomberg BNA→

US Senate and House tax bill differences to be resolved by conference committee: Steptoe & Johnson→

New Zealand announces tax working group, appoints chair

Spanish firm Euskaltax joins Andersen Global

Paradise Papers leak reveals Nike’s use of Dutch CV to hold trademarks and avoid tax: Simon Bowers / ICIJ→

Austrian Supreme Court addresses taxation of corporate groups: KPMG→

Israel circular calls for deemed dividend upon company withdrawals: EY→

LG “Chip” Harter appointed to key US international tax post

Prof proposes “Dual Business Enterprise Income Tax” for US corporate reform: Edward D. Kleinbard / SSRN→