News Europe
Bulgaria Publishes Law for TP Documentation Requirements and Implementation of EU Tax Dispute Directive
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August 15th, 2019
Bulgaria introduced its law for Transfer Pricing documentation requirements and implementation of EU tax dispute directive which incorporated under the Tax and Social Security Procedure Code. The main amendments include: introduction of mandatory transfer pricing documentation requirements and implementation of the EU Tax Dispute Resolution Directive.
Switzerland To Lose Signicant Tax Revenue Due To International Tax Reforms
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July 23rd, 2019
Swiss Treasury claimed that the country could lose up to CHF10 billion of tax revenues which includes cantons and municipalities taxation. The lose caused by changes in corporate taxation rules to capture a larger share of taxes of multinationals based in tax-friendly destinations like Switzerland.
EU Advisory Body Proposes a Method To Allocate Residual Profits From Marketing Intangible
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July 19th, 2019
The EU Advisory Body has proposed a method to allocate residual profits from marketing intangibles with a four-factor formula as a way to adapt global tax rules for the digital age. The European Economic and Social Committee ( EESC ) adopted an opinion about taxation of the digital economy, noting that any changes on the allocation of taxing rights among countries should be coordinated globally, in order to harness the benefits of globalization.
French Parliament Approves The Reduction of Corporate Income Tax Rate
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July 16th, 2019
The French parliament approved legislation shifting the trajectory of the reduction in the corporate income tax rate that already enacted in the 2018 finance law.
Corporate income tax measures .
The UK to Adopt EU Double Taxation Dispute Resolution Regulations
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July 4th, 2019
UK HMRC has launched a technical consultation on the Draft Double Taxation Dispute Resolution (EU) Regulations 2019. The Regulations are for the implementation of Council Directive on tax dispute resolution mechanisms in the European Union.
Dutch Cabinet Submits New Bill Against Tax Avoidance
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July 4th, 2019
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2).
Implementation of ATAD2: Hybrid mismatches .
EU Notes Launch of New Tax Dispute Resolution Mechanism
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July 2nd, 2019
As from June 2019, new EU rules come into force to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively between the Member States, making daily life easier and offering much more tax certainty for businesses and individuals experiencing double taxation issues.
Resolution of tax disputes in the European Union .
Poland Releases Guidance On Transfer Pricing Comparability Analysis
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June 27th, 2019
The Polish Ministry of Finance issued an explanatory note addressing transfer pricing comparability analyses. This rule is binding the taxpayer to be used when the analysis performed to test whether transactions between related parties conducted until the end of 2018 are in line with the arms-length principle.
UK Files A Challenge To European Court To Overturn State Aid Finding On Tax Anti-Abuse Rules
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June 26th, 2019
The U.K. is fighting an order by European Union antitrust chief Margrethe Vestager to claw back allegedly illegal tax breaks from multinationals, adding to the list of potential EU flashpoints ahead of Brexit. According to the tribunals website, Britain filed a challenge with the EU General Court.
The Netherlands Consulting on New Tax Group Regime
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June 20th, 2019
The Netherlands Ministry of Finance has announced the launch of a public consultation on the design of a new corporate tax group (consolidation) regime to replace the current fiscal unity regime, which was recently amended by emergency repair measures as a result of compatibility issues with EU law.
Background .
ECOFIN Removes Dominica From EU Non-Cooperative List
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June 20th, 2019
The Economic and Financial Affairs (ECOFIN) Council decided to further amend the non-cooperative list by removing Dominica from the list.
Current Non-Cooperative Jurisdiction List
Ten EU States Considering German Plan For .2% Tax On Purchases Stock In EU Headquartered Companies
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June 18th, 2019
Financial transaction tax initiated by the German government was under siege, until the European Union finance ministers recently confirmed that the proposal close to be agreed as the minister has discussed the issue on the implementation of 0.2% tax on shares.
Background .
Protocol Signed To Amend The Tax Treaty Between The Netherlands And Switzerland
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June 13th, 2019
The Netherlands has signed a protocol to amend the old tax treaty between the Netherlands and Switzerland. New agreements have been made against tax avoidance.
The Netherlands Establishes Expert Commission To Examine How To Make Multinational Taxation More Fair
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June 13th, 2019
The Dutch government issued an inquiry on how to make multinationals pay their fair share of tax, after public criticism that the government reforms do not go far enough. The government plans to establish an expert commission to examine such cases.
Dutch Supreme Court Rules Non-Continuation Requirement in Liquidation Loss Scheme
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June 11th, 2019
The Dutch Supreme Court ruled on the assessment procedure on non-continuation in liquidation loss schemes. The judge was of the opinion that the affiliation of the continuing company should be assessed when the liquidation is completed.
Finnish Government Introduces Tax Avoidance Measures In Its Tax Plan
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June 6th, 2019
Finland's newly formed center-left government is reportedly planning a number of tax measures to raise an addition EUR 730 million in tax revenue to fund increased spending. The government is also studying possible measures to reduce international tax planning and avoidance, broaden the corporate tax base, and tax dividends and real estate gains of foreign funds and other exempt entities.
European Commission Asks Harmful Member States To Change Tax Practices
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June 6th, 2019
The European Commission has asked the potentially tax aggressive countries such as Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands to address features of their tax system that may facilitate aggressive tax planning. The request was followed a recommendation report to change tax practices.
US Tech Giant Lobbied Ireland To Use Digital Tax As Tax Credit Against Irish Profit
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June 4th, 2019
Facebook Inc. Senior Executives have conveyed their opinion to Ireland’s minister of finance in January about the possibility of offsetting proposed EU digital services taxes against the company’s Irish corporate tax liability.
Background .
Cyprus Drafting Legislation for New Transfer Pricing Regime
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May 31st, 2019
The Cypriotic Ministry of Finance is reportedly finalizing draft legislation for the introduction of a new transfer pricing regime. The regime is to be in line with the latest OECD transfer pricing guidelines.
Ireland To Open To International Tax Changes
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May 28th, 2019
The Ministry of Finance of Ireland, Paschal Donohoe suggests that Ireland should consider a broader concept of how companies are taxed in the modern digitalized world, setting out his country’s stall in a debate that is key to its economy.
Ireland’s Reform Agenda .

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