December 2019

Main

Global Tax 50 2019

Market insight

The unified approach

The evolution of tax functions will accelerate in 2020

Irish banks lose appeal to resist UK PE capital attribution

What can companies do to get more certainty outside APAs?

Media furore targets Netflix over corporate tax

The organisations leading change

Mexico implements BEPS Action 4 to limit interest deductibility

What Mexican tax reform means for foreign investors

Amazon: GloBE proposal must champion simplicity

The US supports GloBE, but global taxpayers are hesitant

Netflix calls for the OECD to focus on revenue, not sales

Unilever turns to UN standards for global digital tax proposals

Too many cooks

Tax Relief

Australia: Tax round-up – Q4 2019

Chile: Government and Senate’s Finance Commission agree on a range of tax changes

China: China releases DTA guidance to tackle red tape

EU: Chances of adopting EU public CbCR directive appears to wane

Germany: Sustaining contract R&D service solutions in a post-BEPS DEMPE context

Greece: Transfer pricing controversy – trends and practical recommendations

Hong Kong: Hong Kong SAR’s long-standing practice on foreign withholding taxes

Indonesia: Tax round-up

Italy: Tax authorities clarify laws on customer list transfers from a company to a permanent establishment

Malta: Patent box regime launched

New Zealand: Inland Revenue updates its multinational enterprises compliance focus

Poland: Application for an AEO authorisation through the EU trader portal

Romania: Transfer pricing controversy on the rise

Russia: Russia’s participation exemption: A clarification

Spain: A quest to locate risk for insurance premium tax

Switzerland: Doing FATCA group requests right

US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise Distribution Regulations

US Outbound: OECD’s unified proposal on pillar one poses challenges for dispute resolution

Cover Story

Global Tax 50 2019

International Correspondents

Australia: Tax round-up – Q4 2019

Chile: Government and Senate’s Finance Commission agree on a range of tax changes

China: China releases DTA guidance to tackle red tape

EU: Chances of adopting EU public CbCR directive appears to wane

Germany: Sustaining contract R&D service solutions in a post-BEPS DEMPE context

Greece: Transfer pricing controversy – trends and practical recommendations

Hong Kong: Hong Kong SAR’s long-standing practice on foreign withholding taxes

Indonesia: Tax round-up

Italy: Tax authorities clarify laws on customer list transfers from a company to a permanent establishment

Malta: Patent box regime launched

New Zealand: Inland Revenue updates its multinational enterprises compliance focus

Poland: Application for an AEO authorisation through the EU trader portal

Romania: Transfer pricing controversy on the rise

Russia: Russia’s participation exemption: A clarification

Spain: A quest to locate risk for insurance premium tax

Switzerland: Doing FATCA group requests right

US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise Distribution Regulations

US Outbound: OECD’s unified proposal on pillar one poses challenges for dispute resolution

Features

Market insight

The unified approach

The evolution of tax functions will accelerate in 2020

Irish banks lose appeal to resist UK PE capital attribution

What can companies do to get more certainty outside APAs?

Media furore targets Netflix over corporate tax

The organisations leading change

Tax Relief

Tax Relief

Special Features

Mexico implements BEPS Action 4 to limit interest deductibility

What Mexican tax reform means for foreign investors

News Analysis

Amazon: GloBE proposal must champion simplicity

The US supports GloBE, but global taxpayers are hesitant

Netflix calls for the OECD to focus on revenue, not sales

Unilever turns to UN standards for global digital tax proposals

Editorial

Too many cooks

Sponsored

Sponsored

Sponsored by Hager & Partners

Italy: Tax authorities clarify laws on customer list transfers from a company to a permanent establishment

Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse the laws on customer list transfers and explain why this has been a problematic area in Italy.

Barbara Scampuddu, December 17 2019
Sponsored by Deloitte Switzerland

Switzerland: Doing FATCA group requests right

Brandi Caruso and Robin King of Deloitte investigate the lessons learned and pitfalls to avoid in responding to FATCA group requests under the Swiss-US double tax treaty.

Brandi Caruso, December 17 2019
Sponsored by Fenwick & West

US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise Distribution Regulations

David Forst and James Fuller of Fenwick & West discuss the recent changes which modify the exisiting Section 385 regulations.

David Forst, December 17 2019

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