brought to you by TPS
Europe
- Italy unlocks tax dispute resolution mechanism – click here
- Italian digital services tax is knocking at the door – click here
- French High Court in Valueclick interprets tax treaty permanent establishment rules – click here
- Dutch informal capital scheme should be investigated for illegal state aid, professor says: Jan Vleggeert / SSRN – click here
- German transfer pricing amendments shift burden of proof, reveal climate of distrust – click here
- CFE’s EU Tax Policy Report – Semester II 2020 – click here
- CFE’s EU Tax Top 5 – Round-up of EU Tax Policy News – 21 December 2020 – click here
Global
- Indian, Italian and Turkish digital service tax discriminatory: US Trade Representative – click here
- Indian court confirms Redington’s use of foreign subsidiaries avoided tax – click here
- Singapore sets indicative margin for related party loans for 2021 – click here
- Barbados ratifies BEPS MLI to tackle MNE tax avoidance – click here
- Malaysia gazettes transfer pricing measures – click here
- Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer – click here
- Singapore ruling concludes that corporation and three foreign shareholders are not related parties for transfer pricing purposes: Inland Revenue Authority of Singapore – click here
- Airbnb is under examination by the Internal Revenue Service for its income taxes in 2013 and 2016, according to the company’s December 2020 SEC filing – click here
- Diageo – British multinational beverage and alcohol group – is facing various tax challenges – click here
- OECD issues guidance on transfer pricing implications of COVID-19 pandemic – click here
- OECD plans public consultation meeting on “blueprints” for taxing large multinationals – click here
- 200+ organizations respond to OECD reports on Pillar One and Pillar Two blueprints – click here
- Taxation of the digital economy: Analyzing user base value – click here
- 2020: The best of transfer pricing – click here
- OECD FT Report: A potential solution to excessive debt financing – click here
DAC 6
- DAC6: resources for your safety! From TPS! – click here
- For the latest developments and news concerning DAC6 – click here
- UK unexpectedly reduces tax scheme reporting burden on firms – click here
- UK to repeal DAC6 in 2021 – click here
- DAC6 in the UK — What now? – click here
- Malta has published the DAC6 Guidelines – click here
- Czech Republic published answers to some DAC6 questions – click here
- Italy started a public consultation on a draft circular intended to provide clarifications on the DAC6 reporting process – click here
- Ireland updates DAC6 guidance – click here
Romania
- Say cheese! How we prepare the tax protection system for intra-group transactions (a post-pandemic perspective) (RO) – click here
- For safe transfer pricing, describe your pandemic correctly! A practical tip from the OECD's "seasonal" guide (RO) – click here
- Rules on the posting of workers between EU countries. What are the obligations of employers? (RO) – click here
- VAT? Claims? Long awaited fiscal measures? Get them out of nowhere! (RO) – click here
- OECD recommendations clarify the implications of the COVID-19 pandemic on transfer pricing (RO) – click here
- What does the beginning of the year look like in taxation and how much can companies expect from state support? (RO) – click here
