Category: EU

Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company

The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading

EU to launch tax observatory

The EU’s awareness of the relevance of tax policy is clear. On 6 July, the European Commission called for proposals for the creation of an EU tax observatory. This follows the adoption of the Commission Decision on the financing of the preparatory action EU Tax Observatory – Capacity building to support Union policy making in the area of taxation and the adoption of the annual work programme for 2020 on 16 June. ... - Continue reading

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading