Articles

A week ago, Greenland was made news that went rather unnoticed, possibly in the safe knowledge that it is somehow linked to the new normal – the island saw, in one day, the melting of 12.5 billion tons of ice! If we are into comparisons, we look at an amount big enough to get the state of Florida covered under 12 cm thick water layer or the whole ...

Getting through to a taxpayer via its tax advisor is no new policy. It first started 20 years ago in the US and moved on to the UK placing intermediaries under an obligation to report the so-called tax avoidance schemes. The EU is now joining the club with an unpredictable experiment enforcing common minimal standards in reporting ”potentially a ...

The French Senate made up its mind (see link). Tired of waiting for a global consensus on the digital advertising tax, which had been repeatedly delayed, the French officials decided unilaterally to introduce a 3% tax on the revenues that digital companies earn from French users. ...

“SA. 38945” could have been just another case about the tax rulings (issued by Luxembourg or other) found unlawful by European Commission. As it was “SA. 38375” (Luxembourg-Fiat Finance), or “SA. 38944” (Luxembourg-Amazon), or “SA. 44888” (Luxembourg-Engie) or the other “ad hoc state aid (S.A.) cases regarding tax base reduction ...

The EU sinks its tax fangs into America's Apple and demands 13 billion dollars 'owed' to Europe. A harsh warning of intolerance to tax arrangements without Brussels' OK. The US grinds its teeth equally harshly, and brutally displays its own intolerance to anyone who might bite into the taxes 'owed' to Uncle Sam. Their warning - hands off our transf ...

The Brexit vote result will change, if it hadn’t already started to, the way in which the EU will approach the most controversial topics – among which, the highly politicized issue of trans-European taxation, where transfer pricing and profit allocation are the key words. The two parties’ position regards after all, the profit allocation – ...

If you read during the week an editorial written by a well-known name here in Romania, not only by economists but also by the general public, you already know that "transfer-pricing practices (of profit export through manipulated transfer prices) are more detrimental for the host country in time of crisis." And if you heard the Minister of Finance ...

It’s easy to castigate politicians for their fiery speeches. On Tuesday (16 July 2019), Outgoing President of the European Council, Donald Tusk, tweeted to inform us that ”I am a fanatic of EU’s unity, (...) When she [Ursula von der Leyen] says that she will be a passionate fighter for Europe's unity and strength, she means it”. A couple ...

Disputes between EU Member States on transfer pricing and other double taxation issues should end quicker and more effectively - according to the Directive on Double Taxation Dispute Resolution Mechanism, which is coming into force as of July 1st, 2019 . ...

Here is the Transfer Pricing Services' "Response to the Roadmap for more efficient law-making in the field of taxation: identification of areas for a move to qualified majority voting (QMV)", which was sent to Brussels on 21 January 2019.     Dear Madam / Sir, Thank you for the opportunity to provide our thoughts on adopting “Qualified Maj ...

The whole tax reform under work nowadays in Brussels is centered on the reformulation of the concept of tax advantage on a national level that does not cause damage on a European level.Which brings us to the intragroup transactions and of their prices - the so-called transfer prices, which the Tax Administration wants at market levels; well, in the ...