06 December 2017

Council of the European Union publishes list of uncooperative jurisdictions for tax purposes

The Council of the European Union (the Council or ECOFIN) published a listing of "Uncooperative jurisdictions for tax purposes" (the listing) on December 5, comprising 17 jurisdictions that were deemed to have failed to meet relevant criteria established by the European Commission (The Commission). The Council also published their conclusions titled Responding to the challenges of taxation of profits of the digital economy, noting that it (the Council), "Looks forward to appropriate Commission proposals by early 2018," and "takes the view that an appropriate nexus in the form of a virtual permanent establishment, together with any necessary corresponding amendments to the rules of transfer pricing and profit attribution, which would take into account where value is created in the different business models of the digital economy, should be explored."

A Global Tax Alert, attached below, provides additional detail.

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ATTACHMENT

Full text of Tax Alert 2017-2066

Document ID: 2017-2066