Category: Activity

European Union: Interpretation And Application Of The General Anti-Abuse Rule Of The Parent-Subsidiary Directive

''Overview of EU Member States and Switzerland'', which gives you a comprehensive overview of the current state of play on the interpretation and application of the EU Parent Subsidiary Directive general anti-abuse rule (Directive 2015/121/EU) in the EU member states and how Switzerland deals with it. ... - Continue reading

Croatia to initiate tax treaty negotiations with the United States

The government of the Republic of Croatia, on September 30, adopted a decision to initiate proceedings to conclude a convention with the United States on the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income. ... - Continue reading

Canada: COVID-19 Just Made Transfer Pricing More Difficult

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term. In an article published by the Gowling WLG Transfer Pricing & Competent Authority Group entitled "CRA Audit Activity: The Calm before the Storm?", it was hypothesized that the Canada Revenue Agency ("CRA") would likely step up audit activity, after the COVID-19 episode is finally behind us, to reign in government deficits. ... - Continue reading