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  • INSIGHT: Fiat State Aid Case—Impact on Luxembourg

    BloombergBy Oliver R. Hoor and Keith O'Donnell

    The General Court of the EU has upheld the decision of the European Commission in the Fiat case, confirming that a tax ruling by the Luxembourg tax authorities conferred an advantage which constituted illegal state aid. Oliver R. Hoor and Keith O’Donnell of ATOZ Tax Advisers (Taxand Luxembourg) discuss the Court’s decision and what it will mean for Luxembourg going forward.

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    By Oliver R. Hoor and Keith O'Donnell, posted on Wednesday December 4, 2019
  • France Endorses OECD Pillar 1 Global Tax Overhaul

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    By: Stephanie Soong Johnston

     France strongly supports the OECD pillar 1 proposal for allocating more taxing rights to market countries and suggests a 12.5 percent rate for global minimum taxation under pillar 2, according to a top official.

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    By Stephanie Soong Johnston, posted on Wednesday November 27, 2019
  • Economic Analysis: How Much New Taxable Profit for Market Countries

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    By: Martin Sullivan 

    In economic analysis, Martin A. Sullivan examines the OECD's attempt to rewire the international source rules so that more taxable profits are allocated to market jurisdictions than currently allowed under the arm's-length rules.

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    By Martin Sullivan, posted on Monday December 2, 2019
  • How Could the United States Implement a Global Tax Deal?

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    By: Mindy Herzfeld 

    Mindy Herzfeld considers what steps the United States would need to take for the OECD’s pillar 1 proposals to become workable for the IRS, as well as for other tax authorities when applied to U.S. taxpayers.

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    By Mindy Herzfeld, posted on Monday December 2, 2019
  • Pillar 1 Profit Formula Should Approximate Arm's-Length Standard

    Tax AnalystsBy Ryan Finley

    The formulas for calculating local distributors’ profit under pillar 1 of the OECD’s two-pillar project on taxing the digital economy should produce results that generally align with the arm's-length standard, according to business representatives and practitioners.

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    By Ryan Finley, posted on Thursday November 28, 2019
  • Crown Dependencies Issue New Substance Guidance for IP Companies

    Tax AnalystsBy Ryan Finley

    The three British crown dependencies have jointly released updated guidance for applying each jurisdiction’s new economic substance rules, with new sections on core income-generating activities of intellectual property companies, shipping, and the insurance industry.

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    By Ryan Finley, posted on Thursday November 28, 2019
  • ECOFIN to Discuss Public CbC Reporting

    Tax AnalystsBy Elodie Lamer

    Ambassadors and tax experts from EU countries recently spoke out against the decision of the Finnish EU Council presidency to try to reach an agreement on public country-by-country reporting by qualified majority.

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    By Elodie Lamer, posted on Thursday November 28, 2019
  • Outside the Box: In Praise of Reverse Transfer Pricing

    Tax AnalystsBy Robert Goulder

    Robert Goulder examines whether reverse transfer pricing could become a viable method to avoid the base erosion and antiabuse tax provisions.

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    By Robert Goulder, posted on Thursday November 28, 2019
  • OECD Must Link Pillar 1 Profits or Face More Double Tax Risks

    Tax AnalystsBy Stephanie Soong Johnston

    The OECD must address the lack of interaction between three categories of company profit that would be taxed under proposed new global tax rules, or else double taxation risks could increase, a trade representative warned.

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    By Stephanie Soong Johnston, posted on Thursday November 28, 2019
  • Up to 15 Multinationals Leave Philippines;Tax Reform Law Cited

    Tax AnalystsBy William Hoke

    The head of a Philippine business association said a tax reform program might be one of the reasons why 10 to 15 multinational companies' regional operating headquarters have pulled out of the country.

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    By William Hoke, posted on Thursday November 28, 2019


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