Mazars US Tax Desk
Another issue of our US Tax Desk newsletter has just been published! This publication provides you with insights on current topical tax issues and discuss how they will affect you.
In this edition, our contributors from 5 European countries discuss:
- Agreement on proposed hybrid mismatches;
- Multilateral instrument to implement BEPS measures into bilateral tax treaties;
- New permanent establishment guidelines;
- Luxembourg transfer pricing circular on financing activities, applicable to the transfer pricing documentation and APA related to financing margin;
- The opinion of the Advocate General at the CJEU presented on 19 January, 2017 on the Eqiom case (C-6/16) on dividend payment from France to Luxembourg;
- Fiscal impact of selling shares in a limited liability company (“GmbH”) at a discount to the GmbH itself; and
- Investing in the UK now that Brexit has been commenced.