MIT Report – CFC rules under ATAD

On 18 February 2019, the MIT hosted Prof Alexander Rust from the Vienna University of Economics and Business, who led a Master Class on Controlled foreign company rules under the Anti-Tax Avoidance Directive: interaction with EU fundamental freedoms and the potential effects on tax planning. A report...

CFE Tax Top 5 – 19 August 2019

This week's edition of the Tax Top 5 looks at the following: GAFA Representatives give evidence at US enquiry into French Digital Tax Apple's appeals against EU Commission decision set for hearing next month OECD publishes Stage 2 MAP Peer Reviews 9th US Circuit Court...

CFE Tax Top 5 – 12 August 2019

This week's edition of the CFE Tax Top 5 looks at the following: US warns no trade deal if UK impose Digital Tax UK seeks annulment of European Commission decision in CFE Cases New signatories to the OECD MLI European Economic and Social Committee adopt...

CFE’s Tax Top 5 – 5 August 2019

This week's edition of the CFE Tax Top 5 looks at the following: Amazon increases referral fees in France following introduction of Digital Tax Global Forum on Tax Transparency publish Compliance Reports European Commission publishes APA and MAP Statistics Germany pushes for European Aviation Tax. The...

Malta – Kosovo Double Tax Treaty

The convention signed between Malta and Kosovo for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was published by virtue of LN 168 of 2019. The Convention will enter into force with effect from such date as...

MIT Master Class delivered by OECD Head of ATP

On 14 June 2019, the MIT had the honour of hosting Mr. John Petersen, Head of Aggressive Tax Planning – OECD, who delivered the MIT Master Class on Transposing ATAD II Anti-hybrid Rules. Mr. Petersen is responsible for Working Party 11 which produced the BEPS Reports...

Mutual Agreement Procedure – CFR guidelines

The Office of the Commissioner for Revenue has issued guidelines on the Mutual Agreement Procedure (MAP) which may be invoked with a view to resolving an international tax dispute, pursuant to the MAP provision in a Double Taxation Agreement or the EU Arbitration Convention (90/463/EEC). The...

Malta – Monaco Double Tax Treaty

In virtue of L.N. 91 of 2019, the Double Tax Treaty between Malta and the Principality of Monaco, as published as a Schedule to Legal Notice 70 of 2019 entered into force on 16 May 2019....