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Luxembourg Archive

  • October 2017

    ECJ clarifies VAT treatment of hire purchase contracts in Mercedes case

    October 12, 2017

    Businesses could find VAT accounting easier after the European Court of Justice (ECJ) ruled that hire purchase-like contracts, which include an option to buy, should be treated as a supply of goods, rather than services, if exercising this option is the lessee’s obvious choice.

  • Business costs to fall as EU agree on MAP

    October 11, 2017

    Ministers of the EU Economic and Financial Affairs Council (ECOFIN) have agreed on a new system for resolving double taxation disputes between member states that could see litigation and compliance costs fall considerably for businesses operating in the EU.

  • EU VAT gap falls ahead of VAT reform to tackle fraud

    October 05, 2017

    The EU hopes that its plan to reform the VAT system, which includes changes to the digital single market, will make it more resilient to the massive level of fraud currently prevalent within its borders.

  • Amazon slapped with €250 million bill for illegal state aid

    October 04, 2017

    Luxembourg will have to reclaim €250 million ($294 million), plus interest, from Amazon for “undue tax benefits” after the European Commission announced its state aid decision in the case. But the amount is surprisingly small and many say the decision doesn’t tackle the real issue.

  • Luxembourg: Guidance issued on the mutual agreement procedure

    October 02, 2017

  • September 2017

    EU to redesign tax net to catch online giants

    September 27, 2017

    The European Commission (EC) will set out a “strong and ambitious” vision on how to tax the digital economy in early 2018, targeting companies such as Google, Amazon, Microsoft and Apple.

  • ITR showcases the best women in tax in its latest guide

    September 25, 2017

    The third edition of the Women in Tax Leaders guide has been released, with several new countries and more than 150 new names included this year.

  • Will EU member states bring in a turnover tax on digital multinationals?

    September 20, 2017

    Ten EU member states agreed that large digital multinational such as Google, Amazon, Apple and Facebook will have to pay their ‘fair share of tax’. However, a lack of consensus around the core proposal for an equalisation tax remains.

  • ECOFIN to consider virtual PE rules to tax digital MNEs

    September 13, 2017

    Multinational technology giants like Google, Amazon, Apple, Microsoft and Facebook could face higher tax bills under EU plans to introduce virtual permanent establishment rules. However, such rules could be difficult for governments to administer.

  • August 2017

    The world’s best tax controversy leaders revealed

    August 29, 2017

    The seventh edition of the Tax Controversy Leaders guide has been released, with more than 300 new names and seven additional countries this year.

  • Tax risk pendulum: Collaboration vs. uncertainty

    August 23, 2017

    Tax risk is a modern ‘term of art’ perception; this risk can be viewed as a pendulum. Keith Brockman looks at the advantages of corporate collaboration and threats of uncertainty and public distrust.

  • Tax havens: An unnecessary evil?

    August 23, 2017

    The finance ministers of some of the world’s most notorious tax havens believe their countries’ policies are fair, robust and meet international standards. Anjana Haines cuts through the PR to see what role these jurisdictions play in an era of BEPS measures and increasing transparency.

  • EU holding company structure in treaty shopping cases

    August 23, 2017

    The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

  • Luxembourg: New BEPS-compliant IP regime to open up opportunities

    August 23, 2017

    Luxembourg has released draft legislation on its intellectual property (IP) box regime that could offer more benefits to companies’ R&D activities.

  • France takes on digital corporations with EU tax harmonisation plans

    August 23, 2017

    The tax payments of Airbnb, Google, Facebook and Amazon have prompted the French finance minister to push, together with Germany, for the EU harmonisation of corporate tax rates. But will this solve the ‘paying a fair share’ argument, or does the problem lie with domestic PE rules?

  • eBay slaps businesses trading in UK with VAT

    August 09, 2017

    Since August 1, eBay has been charging VAT on its fees to businesses trading in the UK in a move to crack down on avoidance schemes. But do the measures go far enough?

  • July 2017

    EU case to set precedent on VAT treatment of rebates for parties outside the distribution chain

    July 27, 2017

    The ECJ will soon rule on a case involving global pharmaceutical company Boehringer Ingelheim that will set a VAT precedent for the pharmaceutical sector. Jan Sanders, indirect tax manager at RELX, discusses the impact of a ruling on this long-debated matter concerning the VAT treatment of supplies outside a distribution chain.

  • Cristiano Bortolotti joins Dentons

    July 20, 2017

    Dentons has strengthened its transfer pricing practice with the appointment of Cristiano Bortolotti as partner.

  • German Fiscal Court on the dilemma of tax neutrality for funds and equal treatment under the EU freedoms

    July 18, 2017

    Under its tax regime, Germany grants a tax exemption only for domestic funds but not for foreign funds. The Fiscal Court Münster (20/04/2017,10 K 3059/14 K) ruled that this is in line with the EU freedoms because the situation of German funds is not comparable to that of foreign funds.

  • European Tax Awards 2017: Winners announced

    July 11, 2017

    Over 30 different firms and individuals won recognition for their unique achievements at this year’s European Tax Awards 2017 held at The Savoy, London.

  • The economics behind EU tax investigations: The way forward

    July 11, 2017

    The European Commission has made some surprising decisions in recent years about how tax rulings between multinationals and EU member states constitute state aid. In the second of this two-part series of articles, Carina Lange, senior consultant at CEG Global in the Netherlands, discusses how multinationals can maintain legal certainty and assess the risks associated with tax rulings.

  • Tax director 2.0

    July 11, 2017

    Tax work is being transformed by technology, and the role of the tax director is changing with it. Joe Stanley-Smith looks at the new tools on offer to businesses, the skills needed to use them properly, and why companies need to jump on the bandwagon sooner rather than later.

  • Luxembourg: Implementation of IGP exemption in VAT Directive too broad

    July 11, 2017

    Luxembourg will have to adjust its rules for determining the application of the "independent group of persons" (IGP) exemption in the EU VAT Directive following an EU court ruling

  • June 2017

    The world’s best indirect tax leaders revealed

    June 29, 2017

    The sixth edition of the Indirect Tax Leaders guide has been released, with more than 200 new indirect tax leaders recognised around the world.

  • Final week to submit nominations for the Women in Tax Leaders guide

    June 26, 2017

    There are only a few days left to nominate the leading women in the tax advisory world for the third edition of the Women in Tax Leaders guide. The submission period closes on June 30.

  • European Commission to crack down on ‘supply side’ of tax avoidance

    June 20, 2017

    Leaked documents reportedly reveal the Commission is seeking to tighten its regulation of what activists term the ‘supply side’ of tax avoidance – the banks, law and accountancy firms that devise aggressive schemes.

  • EU’s public CbCR loophole slammed for failures

    June 14, 2017

    Two European Parliament committees that adopted a draft report on public country-by-country reporting (CbCR) have received heavy criticism over a proposed ‘loophole’ that will allow MNEs to not publically disclose “commercially-sensitive” information.

  • Who benefits from carbon tax increases?

    June 08, 2017

    A recent report calls for a global effort to save the planet by introducing high carbon taxes, but will tough tax measures work and who will gain from them?

  • MLI to create long-term uncertainty in tax planning

    June 07, 2017

    The signing ceremony of the OECD multilateral instrument (MLI) is a big step towards implementing tax treaty-related BEPS recommendations, but the potential for governments to ‘cherry-pick’ treaty amendments risks long-term problems.

  • May 2017

    EU adopts directive to tackle hybrid mismatches

    May 31, 2017

    The European Union (EU) Council has adopted rules to prevent multinationals using hybrid mismatch arrangements to avoid taxation, but the measures risk conflicts with national laws and could give rise to disputes.

  • OECD releases peer review criteria for BEPS Action 6

    May 31, 2017

    Governments have six months to prepare before peer reviews begin on how they meet the minimum standards of the BEPS project, including Action 6 on treaty shopping. But tax authorities could face some difficulties in meeting their targets.

  • The Brockman brief: Double taxation: Does it matter?

    May 30, 2017

    There is one topic that is seemingly silent by tax administrations, non-governmental organisations (NGOs), parliamentarians and international tax bodies: double taxation. Keith Brockman reviews the state of play and what can be done to help multinationals.

  • Talking to the OECD: Tech disruption in tax administration

    May 30, 2017

    Peter Green, head of the Forum on Tax Administration (FTA) Secretariat at the OECD shares his views with the Inland Revenue Authority of Singapore (IRAS) and International Tax Review on how technology is changing the status quo for many industries and tax administrations with the constant emergence of new technologies and rising taxpayer expectations.

  • Transforming tax – under pressure

    May 30, 2017

    Tax departments are feeling the heat. A tsunami of changes is causing them to rethink their purpose and review how they operate. Mark Body, director, tax transformation (financial services) at KPMG in the UK, considers how corporate tax leaders are adapting to the changes, and what the future is likely to hold for them and their teams.

  • Using blockchain for transparent beneficial ownership registers

    May 30, 2017

    The OECD and the Financial Action Task Force (FATF) are considering how to improve implementation of the international standards on transparency, including on the availability of beneficial ownership information and its international exchange. Julia de Jong, Alexander Meyer, and Jeffrey Owens of the Global Tax Policy Centre at the Institute of Austrian and International Tax Law within the Vienna University of Economics and Business explore how blockchain technology could be used to achieve this goal.

  • The economics behind EU tax probes: What it means for you

    May 30, 2017

    Understanding competition economics can help multinationals and national authorities restore and maintain the legal certainty of tax rulings. In the first of a two-part series of articles, Carina Lange, senior consultant at CEG Global in the Netherlands, explains the approach the Commission is taking to assess whether tax rulings or systems distort competition and how it fits into the general economic assessment of state aid cases.

  • EU finance ministers agree on MAP for double taxation disputes

    May 23, 2017

    Businesses operating in the EU could see their litigation and compliance costs fall considerably after the EU Economic and Financial Affairs Council (ECOFIN) agreed on a new system for resolving double taxation disputes within the 27-member bloc.

  • Corporate tax compliance burdens are rising despite lower tax rates and more incentives

    May 17, 2017

    Governments worldwide are seeking alternative means to attract businesses as global tax reforms and weak economic growth drive tax rates down, but the tax changes are anything but positive for businesses.

  • Last chance to submit for World Tax and Transfer Pricing 2018

    May 15, 2017

    The submission period for World Tax and World Transfer Pricing 2018 has ended. Firms interested in making submissions should contact their country's researcher immediately if they have missed the deadline.

  • April 2017

    CbCR nears: Reputational risk perceptions

    April 26, 2017

    Country-by-country reporting (CbCR) deadlines are approaching and MNEs are carefully preparing the information and diligence behind the numbers. CbCR brings us to the next phase and Keith Brockman asks how reputational risk will be questioned by the public (if disclosed) and defended or ignored by MNEs and tax administrations.

  • Indirect Tax Forum: Highlights

    April 26, 2017

    On March 30, International Tax Review hosted its Indirect Tax Forum at the Hyatt Regency Hotel in Düsseldorf, Germany, in association with WTS. The day was a great success, with open dialogue from in-house tax professionals, tax advisers and campaigners. Here, conference host Joe Stanley-Smith presents some of the highlights from the day.

  • Planning it safe: Less risk and more substance

    April 26, 2017

    Tax planning is adapting to reflect a more transparent and technological world, bringing with it a change in attitudes and new challenges for taxpayers. The decisions made now should not be underestimated as they could have unexpected consequences later.

  • CRS allows taxpayers to avoid detection as loopholes remain

    April 26, 2017

    Financial institutions are busy filing their first reports to tax authorities to comply with the common reporting standard (CRS), but loopholes in the global measure mean some taxpayers can remain undetected. Amelia Schwanke highlights the gaps appearing and the jurisdictions enabling them.

  • Proposed new tax regime targets real estate in Sweden

    April 26, 2017

    Sweden plans to introduce new rules on the taxation of commercial real estate that may complicate tax credits for foreign taxpayers and potentially result in double taxation. Richard Hedin Thyr, tax partner, and Hussein Abdali, tax adviser, at Skeppsbron Skatt, Taxand Sweden, analyse what these proposals could mean.

  • Luxembourg: The latest weapon in the fight against BEPS: The MLI

    April 26, 2017

    The signing ceremony for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (MLI) is due to take place on June 7 2017. What will this treaty mean for you?

  • March 2017

    World Tax and World Transfer Pricing submissions open

    March 29, 2017

    The research period for World Tax and World Transfer Pricing 2018 has now begun. Firms interested in making submissions can download the relevant forms from this page.

  • Brexit: Knowing the unknowns for taxation

    March 23, 2017

    Dealing with the known unknowns is all any business can seek to do in the uncertain environment, whether it stems from the US or the UK. Cormac Kelleher, international tax partner at Mazars in Dublin discusses the plethora of unknowns and how companies can navigate through it all.

  • Bridging the digital gap: How tax fits into cryptocurrencies and blockchain development

    March 23, 2017

    The world is on the cusp of a major tax revolution as cryptocurrencies and online distributed ledger technologies, such as blockchain, push financial systems from the physical world to online. Amelia Schwanke speaks to the experts in a roundtable discussion about the tax implications and usage of digital currencies and blockchain.

  • Technology solutions in a post-BEPS world

    March 23, 2017

    There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the OECD’s BEPS Project. JD Choi, CEO at Tax Technologies, explores the technology solutions that should be administered to mitigate these audit risks in a post-BEPS world.

  • Inter-group financing by MNEs faces imminent change in the US

    March 23, 2017

    The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

  • Luxembourg: Income threshold for non-residents to gain residency benefits to be put to the test

    March 23, 2017

  • Luxembourg appoints new director of taxation

    March 17, 2017

    Carlo Fassbinder has become the new Director of Taxation at Luxembourg’s Ministry of Finance.

  • Antoine Deltour: LuxLeaks whistleblower speaks out

    March 15, 2017

    Antoine Deltour, one of the two whistleblowers at the centre of the LuxLeaks scandal, said that he had “mixed feelings” after his conviction for leaking confidential information was upheld, but his sentence was reduced.

  • LuxLeaks whistleblowers' appeal crushed

    March 15, 2017

    In a massive blow to tax transparency and whistleblower campaigners, Antoine Deltour and Raphaël Halet have failed in their quest to be acquitted for the LuxLeaks scandal in an appeal against an earlier verdict.

  • A brief timeline on the developments of the LuxLeaks case

    March 15, 2017

    ITR breaks down the developments that led to the conviction of former PwC employees Antoine Deltour and Raphaël Halet, who exposed more than 300 multinational enterprises benefiting from sweetheart tax deals with the Luxembourg authorities to avoid taxes in Europe.

  • Webinar: Transfer pricing issues for MNEs investing in Africa

    March 13, 2017

    Recent studies show that the African continent is attracting a growing amount of investments from foreign multinational enterprises. BonelliErede and International Tax Review will provide an overview of the main transfer pricing issues to consider for structuring investments into selected countries.

  • ECJ stands firm on e-books standard VAT rate

    March 10, 2017

    The European Court of Justice (ECJ) has reiterated its stance on the controversial issue of taxing e-books in a decision against Poland.

  • New Director for Indirect Taxation and Tax Administration at the European Commission

    March 09, 2017

    The European Commission has decided to appoint Maria Teresa Fabregas Fernandez as its Director for Indirect Taxation and Tax Administration. She takes over the role from Donato Raponi on March 16.

  • February 2017

    The Brockman brief: Tax haven blacklist: Talk of the town

    February 28, 2017

    As EU member states determine the criteria for what constitutes a tax haven, while at the same time lowering their tax rates, the debate over tax havens is growing. Keith Brockman considers the parameters of the ideas of ‘transparency’ and ‘tax haven blacklist’.

  • GE/PwC deal advances trend to outsource tax functions

    February 28, 2017

    With corporations meeting the demands of rapidly changing regulations, increased audits, and new tax technology functions, some are overwhelmed with how much tax is influencing their business strategy – leading to a number of outsourcing arrangements. Amelia Schwanke explores whether General Electric (GE) and PwC’s recent agreement has ignited a new trend for outsourcing a business’s tax function

  • Inside M&A: Welcome to the Tax Transactional Survey 2017

    February 28, 2017

    International Tax Review’s flagship tax transactional feature looks at the global M&A market during 2016, explores the tax trends in major deals that may continue into 2017, and provides a breakdown of the leading firms in transactional advice across multiple jurisdictions.

  • Luxembourg: Views on the Luxembourg tax reform

    February 28, 2017

  • Nominations open for Tax Controversy Leaders guide

    February 27, 2017

    The research period for the seventh edition of International Tax Review’s Tax Controversy Leaders guide has begun.

  • Nominations open for Indirect Tax Leaders guide

    February 13, 2017

    The research period for the sixth edition of International Tax Review's Indirect Tax Leaders guide has begun.

  • Transatlantic tax tensions grow over business poaching

    February 08, 2017

    EU leaders are queuing up to criticise the US and UK over plans to slash corporation tax, while US President Donald Trump makes provocative comments on the European project. The growing conflict means corporate CEOs are left scratching their heads on tax planning and whether to shift manufacturing, IP and profit into the US.

  • EU Advocate General: UK and Gibraltar ‘one entity’ for tax issues

    February 01, 2017

    Companies could continue to face a double tax charge after an Opinion from a European Court of Justice (ECJ) advocate general said that the UK and Gibraltar should be treated as a single entity for tax purposes in the high-profile Gibraltar Betting and Gaming Commission case.

  • January 2017

    European Tax Awards 2017: Final week for submissions

    January 30, 2017

    Companies and firms have one week left to enter for the European Tax Awards 2017.

  • Final days to vote for the top tax transactional and tax planning firms

    January 26, 2017

    Two forthcoming issues of International Tax Review will include surveys of the leading tax transactional (March) and tax planning firms (May) around the world. This is your opportunity to vote.

  • The Brockman brief: Leadership attributes: developing relationships

    January 25, 2017

    Tax professionals from all areas of the tax sphere need to move outside their comforts zone to grasp the opportunities available and boost skills. Keith Brockman highlights the need for internal and external networking that could offer previously unknown possibilities.

  • M&A considerations for 2017: Don’t let tax derail the deal

    January 25, 2017

    Tax considerations will never make a deal, but they certainly can break a deal. Laurence Field, a senior tax and corporate business partner at national audit, tax and advisory firm Crowe Clark Whitehill, reflects on the M&A tax landscape that evolved through 2016 and looks ahead to assess what businesses need to know if they are planning to get a transaction over the line in 2017.

  • General VAT reverse charge: The view from Central Europe

    January 17, 2017

    Austria, Bulgaria, the Czech Republic, Hungary and Slovakia are seen as the key supporters of the European Commission’s generalised reverse charge mechanism (GRCM), but not all industries or multinationals in these countries will benefit from it.

  • Global VAT reform takes on new impetus in 2017

    January 11, 2017

    In 2017, governments in Europe and around the world will divert their energies away from austerity VAT hikes aimed at combating various financial crises to refining their indirect tax regimes to fight fraud and help promote their economic priorities.

  • EC delves deeper into Engie’s tax affairs

    January 10, 2017

    French electric utility company GDF Suez group (now Engie) could face a tax bill of around €300 million ($318 million) if the European Commission upholds its preliminary decision that the company received illegal state aid benefits from Luxembourg via tax rulings that go as far back as 2008.

  • No more secret tax rulings in the EU?

    January 10, 2017

    The European Union’s new transparency rules for tax rulings have entered into force, but will it really be the end of secret or controversial tax rulings?

  • EU to take ‘nuclear option’ on VAT fraud and allow reverse charge systems

    January 06, 2017

    The European Commission (EC) plans to take drastic action to tackle the €50 billion ($53 billion) in annual EU cross-border VAT fraud by allowing member states to deviate from the VAT Directive.

International Tax Review Profile

RT @CBItweets: UK needs a Budget that enables the country to grow its way out of austerity. Here are 5 business priorities https://t.co/CAw

Oct 19 2017 09:19 ·  reply ·  retweet ·  favourite
International Tax Review Profile

This year's World Tax directory is now online. How does your firm stack up? https://t.co/CtRbW1Ub5j

Oct 19 2017 09:13 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Let's honour the #memory of a brave #journalist and woman ➡️ vigil tomorrow, 18 Oct, 6pm, in front of Residence Palace #Da…

Oct 18 2017 04:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Big Soda scores victory as Chicago-area tax repealed - could this be the beginning of the end of the sugar tax trend?https://t.co/PNuafWHy9K

Oct 12 2017 04:03 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ebay and Netflix pay total UK tax of less than £1.9m - How long until HMRC investigate their TP practices? https://t.co/VPPsT3aGMZ via @FT

Oct 12 2017 03:59 ·  reply ·  retweet ·  favourite
International Correspondents