July/August 2019

Main

Only one way out: Simplifying CFC regimes

Global minimum taxation: A matter of time

European Tax Awards 2019: The winners

Tax Advisory Survey 2019

How global tax reforms apply to the extractive industries

UK tax transparent funds: Five years on from the first launch

India’s angel tax

How concerned should companies be about data they send to tax authorities becoming public?

Market insight: People moves

Tax transformation: What companies need to know

Italy addresses double taxation arising from foreign TP adjustments

Transfer pricing controversy and governance challenges in Luxembourg

Russia’s 20-year evolution of transfer pricing practices

Qualified majority voting will drive reforms, says EC’s tax chief

Taxpayers confident UK will follow EU state aid rules in no-deal Brexit

Companies measure tax departments on their ability to cut risk, not effective tax rates

Businesses disappointed with OECD’s digital tax progress

Residence-by-investment schemes continue to create tax loopholes

US companies fear TCJA amendments by Democrats

Tax heads encourage more companies to use ICAP

Case study: Shell’s participation in ICAP

Case study: Repsol’s participation in ICAP

The negative aspects of ICAP

OECD won’t rush ICAP expansion despite scheme’s popularity

Out with the old, in with the new

Tax Relief

Argentina: New tax promotional regime for knowledge-based activities

Chilean tax reform includes VAT exemption modification

Germany: Relocations of functions and adjustment payments

Greece: Greece adopts EU ATAD I

India: Demystification of scope for claiming tax treaty benefits – welcome stride for foreign investors

Indonesia exempts taxpayers from late submission penalties

Israel: Tax authorities provide certainty on foreign fund investments

Italy: Undisclosed dependent agent PE in Italy: Trends and operational impacts

Luxembourg: Luxembourg adopts exit tax rules aligned with ATAD 1

Malta: Malta publishes tax grouping rules

Mexico: The decree to end all tax pardon decrees

New Zealand proposes interim digital services tax

Poland: Obligatory split payment mechanism and white list of VAT taxpayers introduced

Romania: EC pushes Romania to revise statute of limitation on customs debts

Russia: First ruling on foreign company’s Russian tax residency for VAT

Spain: Spanish National Appellate Court says transfer pricing adjustments to the median must be grounded on comparability defects

Switzerland: Swiss corporate tax reform bill to apply from 2020

US: Sale of a partnership interest: Withholding tax

Cover Story

Only one way out: Simplifying CFC regimes

International Correspondents

Argentina: New tax promotional regime for knowledge-based activities

Chilean tax reform includes VAT exemption modification

Germany: Relocations of functions and adjustment payments

Greece: Greece adopts EU ATAD I

India: Demystification of scope for claiming tax treaty benefits – welcome stride for foreign investors

Indonesia exempts taxpayers from late submission penalties

Israel: Tax authorities provide certainty on foreign fund investments

Italy: Undisclosed dependent agent PE in Italy: Trends and operational impacts

Luxembourg: Luxembourg adopts exit tax rules aligned with ATAD 1

Malta: Malta publishes tax grouping rules

Mexico: The decree to end all tax pardon decrees

New Zealand proposes interim digital services tax

Poland: Obligatory split payment mechanism and white list of VAT taxpayers introduced

Romania: EC pushes Romania to revise statute of limitation on customs debts

Russia: First ruling on foreign company’s Russian tax residency for VAT

Spain: Spanish National Appellate Court says transfer pricing adjustments to the median must be grounded on comparability defects

Switzerland: Swiss corporate tax reform bill to apply from 2020

US: Sale of a partnership interest: Withholding tax

Features

Global minimum taxation: A matter of time

European Tax Awards 2019: The winners

Tax Advisory Survey 2019

How global tax reforms apply to the extractive industries

UK tax transparent funds: Five years on from the first launch

India’s angel tax

How concerned should companies be about data they send to tax authorities becoming public?

Market insight: People moves

Tax Relief

Tax Relief

Special Features

Tax transformation: What companies need to know

Italy addresses double taxation arising from foreign TP adjustments

Transfer pricing controversy and governance challenges in Luxembourg

Russia’s 20-year evolution of transfer pricing practices

News Analysis

Qualified majority voting will drive reforms, says EC’s tax chief

Taxpayers confident UK will follow EU state aid rules in no-deal Brexit

Companies measure tax departments on their ability to cut risk, not effective tax rates

Businesses disappointed with OECD’s digital tax progress

Residence-by-investment schemes continue to create tax loopholes

US companies fear TCJA amendments by Democrats

Tax heads encourage more companies to use ICAP

Case study: Shell’s participation in ICAP

Case study: Repsol’s participation in ICAP

The negative aspects of ICAP

OECD won’t rush ICAP expansion despite scheme’s popularity

Editorial

Out with the old, in with the new

Sponsored

Sponsored

Sponsored by Deloitte Luxembourg

Transfer pricing controversy and governance challenges in Luxembourg

Luxembourg’s stability and innovative culture has made it a global leader in the financial services sector. However, the greater interaction between the tax and regulatory dimension is creating complex tax governance and controversy challenges. Deloitte Luxembourg’s Ralf Heussner and Enrique Marchesi-Herce explore the impact BEPS changes will have on Luxembourg and its financial services sector

Enrique Marchesi-Herce, July 11, 2019
Sponsored by Garrigues Spain

Spain: Spanish National Appellate Court says transfer pricing adjustments to the median must be grounded on comparability defects

On March 6 2019, the Spanish National Appellate Court (NAC), in a particularly relevant transfer pricing judgement, ruled on the selection of the point in the range of values of a sample obtained from a benchmarking analysis to justify the arm’s-length nature of intra-group prices.

Alejandra Aguirre, July 10, 2019
Sponsored by Fenech & Fenech Advocates

Malta: Malta publishes tax grouping rules

The recently published Consolidated Group (Income Tax) Rules, 2019, grant groups, as defined therein, the option to be treated as a single ‘fiscal unit’ for income tax purposes.

Rosanne Bonnici, July 10, 2019

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