Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium
Raphaël Devroye – Transfer Pricing Manager at PwC Belgium
In a recent judgement[1], the Belgian Court of Appeal of Ghent…
On 20 May, 2021 the first Webinar of IFA’s online series “A conversation on International Tax Practice” was held. Chaired by Robert Danon (Chair IFA Permanent Scientific Committee), global experts…
Introduction
On November 23, 2020 Italian Tax Authorities (“ITA”) issued the Provision no. 360494/2020 (“Provision”) by which it introduced new measures[1] as for the content and validity of the…
1. Background
During the 21st Session of the UN Committee of Experts on International Cooperation in Tax Matters, the relevant members decided to include a new draft - Art. 12B on Automated Digital…
Summary
There might be a leak in the OECD’s global minimum tax proposals (GLOBE; Pillar Two). To address the remaining challenges of base erosion and profit shifting (BEPS) by large multinational…
Claudio Cipollini (Heidelberg University, Germany) / February 24, 2021
The identification of new instruments to improve the efficiency of transfer pricing (TP) control is a priority on the…
On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations as well as to increase its openness and transparency. In this respect,…
Purpose of the blog: To analyze the recent ruling of the US tax court (‘the Court’) in the case of The Coca-Cola Company (TCCC).
Ruling: The US Tax Court, for the years 2007-09, ruled TCCC was under…
1. Carve-out of financial services from the scope of Amount A
According to the Report on the Pillar One Blueprint,[1] the proposed scope of Amount A is designed to capture multinational groups that…
