The European Council stated that a number of jurisdictions have not taken sufficient steps to implement their commitments by the agreed deadline, nor engaged in a meaningful dialogue that could lead to such commitments. Subsequently, the Council revised the EU list of non-cooperative jurisdictions for tax purposes. Annex I – black list The EU included...

Latvia published the law with amendments to the Corporate Income Tax Act in its official gazette. The law entered into force on February 12, 2020. Hybrid mismatch measures Article 71 of the law concerns hybrid mismatch measures. Hybrid mismatch means a situation in which a taxable person engages in activities of an affiliate, of an affiliate,...

The German Ministry of Finance published a consultation agreement between the competent authorities of Germany and the Netherlands. The agreement concerns the implementation of the Mutual Agreement Procedure (MAP) under the Double Taxation Agreement (DTA) of 2012, as amended by the protocol of 2016. As stated in the consultation agreement, the competent authorities in Germany...

The Australian Taxation Office (ATO) announced that it is reviewing international arrangements that mischaracterise Australian activities connected with the development, enhancement, maintenance, protection and exploitation (DEMPE) of intangible assets. Concerns are that these arrangements may be non-arm’s length or structured to avoid tax obligations, resulting in inappropriate outcomes for Australian tax purposes. Issues One of...

The Federation of German Industries (FDI) hosts its annual tax conference, addressing the tax challenges or the digitization of the economy. In this conference, among others OECD tax officials discussed the status of Pillar 1 and 2. Moderators and panelists during the event were Pascal Saint Amans (Director of the OECD Center for Tax Policy...

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