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 KPMG Hong Kong

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

Lewis Lu and Curtis Ng of KPMG look at changes by Hong Kong SAR’s Inland Revenue Department to its foreign withholding tax treatment that could increase of the cost of doing business for multinational groups

Curtis Ng, December 17 2019
Sponsored by Nera

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

Managing Director Yves Hervé and Associate Director Philip de Homont of NERA Economic Consulting explain how, and under which circumstances, cost-plus solutions for contract R&D arrangements can be sustained in a post-BEPS age.

Philip de Homont, December 17 2019
Sponsored by PwC

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

Bob van der Made of PwC looks at the EU's progress on public country-by-country reporting (CbCR) and the deadlock that has emerged.

Bob van der Made, December 17 2019

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