European U.S. Tax Desk Newsletter - April 2017

Welcome to the third issue of the Mazars European U.S. Tax Desk Newsletter! 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.

On behalf of the Mazars European U.S. Tax Desk, we hope you find our newsletter useful. If there are any issues you would like to discuss further, please do not hesitate to contact us.

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