Bloomberg Tax
Transfer Pricing Report

Amazon Wins Court Boost in €250 Million Tax Fight With EU Inc. won another boost in its fight over the €250 million ($268 million) bill it was ordered to pay amid a European Union crackdown on allegedly unfair tax breaks for multinational companies.

Apple, Nike Avoid New Tax on Stock Buybacks By Speeding Them Up

The companies may have had other reasons for buying back so many shares when they did. Still, the jump in repurchases appears to poke a hole in the conventional thinking that the 1% buyback tax implemented in January has been too small to affect companies’ behavior.

House Republicans Object to German IP Tax in Letter to Yellen

House Republicans are urging Treasury Secretary Janet Yellen to “protect US taxpayers” against Germany’s century-old tax on intellectual property income that’s been a headache for companies.

Treasury Plans More Guidance on Intellectual Property Transfers

The IRS is planning further guidance on transfers of intellectual property out of and into the US, to address questions that weren’t dealt with in proposed rules issued in May, a Treasury Department official said Wednesday.

Canada Launches Transfer Pricing Reform Triggered by Cameco Tax Case

Canada released long-awaited proposals to reform its transfer pricing rules by making them more precise and clarifying how tax authorities would apply the arm’s length principle when determining whether transactions are in breach of the rules.

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Austria MOF Clarifies Taxation of Director’s Salary Under DTA With Japan

The Austrian Federal Ministry of Finance June 5 clarified the taxation of a director’s salary who resided in Japan but had temporarily established a place of residence in Austria. The ...

Spain Gazettes Order Approving Tax Year 2022 Income Tax Filing Requirements for Corporations, Permanent Establishments

The Spanish Official Gazette May 29 published Order No. HFP/523/2023, approving the 2022 forms and instructions for corporate taxpayers and permanent establishments (PEs). The order includes measures: 1) approving Form ...

Latvia Gazettes Texts of DTAs, Protocol With Czech Republic, Iceland

The Latvian Official Gazette June 5 published the texts of the DTA with the Czech Republic, signed Oct. 25, 1994, and the DTA and protocol with Iceland, signed Oct. 19, ...