In the first of his regular articles for Tax Journal*, Tim Sarson, the new author of the monthly international briefing, rounds up recent international developments. This month’s article looks at:
- The recent EU State aid decision relating to Apple and Ireland, and the response from the US;
- An amendment to the-then Finance Bill 2016 paving the way for public Country by Country (CbC) reporting;
- An update on activity over the summer on the OECD base erosion and profit shifting (BEPS) Action Plan;
- An update on the EU’s ‘tax haven blacklist’;
- A referral to the Court of Justice of the European Union (CJEU) on a German transfer pricing case;
- The opinion of the Advocate General (AG) that Spanish rules on the amortisation of goodwill constitute State aid;
- Changes to the Irish tax rules surrounding investments in real estate;
- Luxembourg 2017 tax reform; and
- In Poland, a court decision on cash pooling arrangements, and the tax authorities focus on transfer pricing.
*First published in Tax Journal on 30 September 2016. Reproduced with permission.