International

  • January 30, 2024

    Latvia Delaying Global Minimum Tax Until 2029

    Latvia's executive body voted Tuesday to delay carrying out the European Union's directive on the global corporate minimum tax until 2029 under an exception afforded to member countries with little to no in-scope companies doing business there.

  • January 30, 2024

    India's APA Network Rivals Germany And China, Report Says

    India's tax authority has accrued roughly the same number of bilateral advance pricing agreements as Germany and China despite beginning its program later, but scaling to meet demand will present challenges, two officers at the Indian Revenue Service said in a brief.

  • January 30, 2024

    French Court Won't Revive Case Against FATCA Transfers

    France's highest administrative court on Tuesday upheld a decision from the country's data protection agency, which had tossed a challenge against the transfer of financial information about certain individuals to U.S. tax authorities under the Foreign Account Tax Compliance Act.

  • January 30, 2024

    Spain Implementing Digital Platform Reporting Rules

    Spain's government approved a measure Tuesday adopting the European Union's tax information reporting procedures for digital platform operators, known as DAC7, as well as standards in line with the OECD's automatic exchanges of information.

  • January 30, 2024

    Spencer Fane Adds Tampa Tax Partner From Gunster

    Spencer Fane LLP has added a partner focused on corporate and tax matters from Florida firm Gunster to its Tampa office.

  • January 30, 2024

    EU Gives More Time For Carbon Import Reporting After Glitch

    Companies that a system glitch prevented from filing required information related to the European Union's new fee on carbon-intensive imports will have extra time to submit the information, the European Commission said.

  • January 30, 2024

    Ex-Freshfields Lawyer Gets 3½ Years In €389M Cum-Ex Case

    A former top tax lawyer for Freshfields Bruckhaus Deringer LLP was sentenced Tuesday to three-and-a-half years in prison by a regional German court for his role in a cum-ex scheme that cost tax authorities €389 million ($421.5 million), according to a local news agency.

  • January 30, 2024

    IMF Warns UK Against Tax Cuts Amid Financial Strains

    The International Monetary Fund said Tuesday that it is advising the U.K. government to not make tax cuts in the upcoming spring budget because it needs to maintain public spending.

  • January 30, 2024

    Employee Faking Invoices Can Be Liable For VAT, ECJ Says

    A Polish fuel seller's employee using her company's details without its consent to issue fraudulent value-added tax receipts can be held liable for paying the VAT, provided that the company took appropriate anti-fraud measures, the European Court of Justice ruled Tuesday.

  • January 30, 2024

    EU Opens Probe Into Swedish Tax Breaks For Biogas

    The European Commission has opened a probe to determine if two Swedish tax exemption schemes for nonfood-based biogas and biopropane used for heating are in line with the European Union's state aid rules, the commission said Tuesday.

  • January 29, 2024

    Int'l Pricing Method Much Faster Than Others, Report Says

    Tax authorities under a multilateral program assessed risks associated with a company's transfer pricing positions in less than half the time of other methods, according to a report published Monday.

  • January 29, 2024

    R&D Credit Amendments Proposed For UK Finance Bill

    A pair of amendments that would further adjust the treatment of research and development tax credits in the latest U.K. finance bill to avoid double-counting were published by HM Revenue & Customs on Monday.

  • January 29, 2024

    Norway Agencies Want More Transparent Ownership Info

    It is too difficult for relevant agencies to determine the true owners of real estate and stocks in Norway, especially when they are foreign owners, three Norwegian agencies said in a survey released Monday.

  • January 29, 2024

    Tax Group Of The Year: Sullivan & Cromwell

    Sullivan & Cromwell LLP's tax practice advised Abiomed on the tax aspects of its acquisition by Johnson & Johnson in the largest medtech deal in history last year, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 29, 2024

    HMRC Started Over 1,000 Serious Tax Probes In 2022-23

    The U.K. tax authority launched more than 1,000 serious tax investigations in the fiscal year ended March 31, 2023, following a yearly increase in tax evasion and avoidance, Pinsent Masons LLP said on Monday.

  • January 29, 2024

    EU Member States Extend Sanctions Against Russia

    The European Union decided to roll over existing economic sanctions against Russia because of its war against Ukraine for another six months until July 31, the council of member countries said Monday. 

  • January 26, 2024

    US Proved Daughters Fraudulently Moved $1.4M, Court Says

    The U.S. government proved that two daughters fraudulently transferred $1.4 million to their U.S. bank accounts from their mother's Israeli bank, but it failed to name and support the amount of damages it seeks, a Florida federal court said.

  • February 08, 2024

    Law360 Seeks Members For Its 2024 Editorial Boards

    Law360 is looking for avid readers of its publications to serve as members of its 2024 editorial advisory boards.

  • January 26, 2024

    Hungary Adjusts Pharmaceutical Tax To Conform To Pillar 2

    Hungary amended a special tax rate for pharmaceutical manufacturers to conform to the Organization for Economic Cooperation and Development's global corporate minimum tax, the country's Ministry of Finance said Friday.

  • January 26, 2024

    HMRC Transfer Pricing Inquiries Took 5 Months Longer

    HM Revenue & Customs fielded fewer transfer pricing inquiries in 2022-23 compared with the prior tax year, but the time it took to close them went up by almost five months, according to statistics released by the British tax authority.

  • January 26, 2024

    Bipartisan Tax Break Bill Faces Rocky Road To Passage

    A bipartisan tax bill that quickly cleared the House's tax panel faces a tumultuous path forward in the full chamber, where Speaker Mike Johnson, R-La., needs to either have robust bipartisan support to pass the bill or risk opening it up to changes.

  • January 26, 2024

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP secured local and global victories in 2023, from a Washington state appellate court's decision in a novel sales tax case to an energy company's $307 million merger resulting in a business with an Africa exploration and production focus, earning the firm a spot among Law360's Tax Groups of the Year.

  • January 26, 2024

    EU Defends Latest Economic Sanctions Against Russia

    The European Union on Friday defended its new round of economic sanctions to be imposed on Russia against claims from the Kremlin that all EU sanctions are illegal and harm Europe and the world.

  • January 26, 2024

    Biz Lobby Urges That BEFIT Wait On Stable Global Tax Rules

    A European business lobby criticized a new draft framework for corporate taxation in the European Union, saying it does not achieve its goals of reducing compliance costs and simplifying the tax landscape and should be delayed until global tax rules stabilize.

  • January 26, 2024

    US Expatriations Rise In 4th Quarter, IRS Says

    The number of people who expatriated from the U.S. jumped nearly 45% during the fourth quarter of 2023 compared with the previous quarter, the Internal Revenue Service said in a notice published Friday.

Expert Analysis

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

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    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Digital Taxation Is Necessary, But Tough To Manage

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    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • Company Considerations For Cash Award Incentives: Part 2

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    Cash awards can help companies address some issues associated with equity awards to compensate employees, but due to potential downsides, they should be treated as a tool in a long-term incentive program rather than a panacea, say Denise Glagau and Kela Shang at Baker McKenzie.

  • Company Considerations For Cash Award Incentives: Part 1

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    Denise Glagau and Kela Shang at Baker McKenzie discuss what companies must consider when offering cash awards outside of U.S. jurisdictions, and explain how some challenges associated with equity awards may be addressed with cash awards.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

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    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

  • Unpacking The New Stock Buyback Tax And Its Exceptions

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    Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.

  • Inside The OECD Transfer Pricing Documentation Guidance

    Excerpt from Practical Guidance
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    The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.

  • Key Takeaways From IRS Reversal On FDII Stance

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    The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.

  • New Tax Decree Suggests Expansion In Dutch Transfer Pricing

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    A July 1 decree from Dutch tax authorities updating transfer pricing guidance heralds a major change in how intercompany financial transactions are considered for transfer pricing purposes and forebodes significant audit activity, say Monique van Herksen and Clive Jie-A-Joen at Simmons and Simmons.

  • Is NJ's Voluntary Transfer Pricing Initiative Really Voluntary?

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    The New Jersey Division of Taxation's voluntary transfer pricing audit initiative promises penalty abatement to taxpayers that elect to participate and agree to the division's proposed adjustments, but the effective penalties associated with nonparticipation raise questions about the program's voluntary nature, say attorneys at McDermott.

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