The Netherlands goverment supports expanding public release of country-by-country data beyond the extractive and banking industries to all companies, Eric Weibes, State Secretary of Finance . . .
The European Commission on March 26 made a formal request to Belgium to amend dividend taxation rules to comply with the parent-subsidiary directive. The Belgian law does not allow . . .
The European Commission on March 16 released the first report of the Expert Group on Automatic Exchange of Financial Account . . .
The European Commission, on August 22, took another step toward addressing concerns that the Netherlands’ corporate tax exemption for Dutch public enterprises violates state aid, asking . . .
The EU Joint Transfer Pricing Forum has released statistics for 2014 on EU nation advance pricing agreements (APAs) and on pending . . .
The EU Commission will address the tax bias that favors debt over equity as a part of its proposal for an EU-wide common consolidated corporate. . .
The European Commission has announced that its current view is that Belgium’s excess profits tax ruling system provides for a selective advantage tantamount to State aid, and has requested stakeholder comments on this determination by July 5. According to the Commission, about 50 companies have used the program to reduce . . .
The European Commission on Sept. 30 published non-confidential versions of its decisions to open state aid investigations into private rulings granted to Apple in Ireland and Fiat in Luxembourg. . .
The EU Commission has appointed 34 organizations and 12 individuals . . .
OECD tax officials have expressed dissatisfaction with a blacklist of 30 tax havens prepared by the European Commission, as have several countries on the list . . .
The EU Commission may propose a mandatory common consolidated corporate tax base (CCCTB) in its action plan to be released next month, Commission Vice-President for the Euro and Social Dialogue, Valdis Dombrovskis, said May 27. Speaking to reporters after a meeting of the EU College of Commissioners, Dombrovskis confirmed that the CCCTB . . .
Tax authorities from 51 jurisdictions have signed a multilateral competent authority agreement, laying the groundwork for automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2017 . . .
The European Commission announced on October 16 that it is referring Belgium to the European Court of Justice for discriminatory taxation of collective investment undertakings
. . .
The UK’s financial secretary to the Treasury, David Gauke, told German MEP Michael Theurer on June 18 that the UK will oppose an EU-wide common consolidated corporate tax base (CCCTB) because the UK prefers tax competition, The Guardian reports. See. The Guardian.
The European Commission on February 6 invited interested parties to comment on its state aid investigation into whether an advance pricing agreement (APA) granted by Luxembourg to Amazon that set the price of intra-group royalties. . .
The US government is trying to persuade the EU Commission that it is inappropriate to require EU States to recover “retroactive” tax from multinationals upon a finding that illegal State aid was provided through overly-generous private tax rulings, Robert Stack . . .
The European Commission on July 13 released a study exploring policy options designed to make the EU VAT system fairer to business engaged in cross-border trade. The EC-commissioned study, prepared by EY, finds t . . .
The European Commission on June 17 said it is readying a proposal for an EU-wide common consolidated corporate tax base (CCCTB) that would be mandatory for multinationals. The Commission also announced plans to publish guidance on intellectual property regimes and transfer pricing; launched a public consultation on whether companies should be required to make . . .
The European Commission will challenge Spanish laws governing the taxation of dividends distributed by a non-resident companies to Spanish companies in the European Court of Justice, the Commission announced November 26. The Commission said that Spain . . .
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
The European Commission on November 14 published its preliminary opinion that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The inquiry, first announced in June, is one of four state aid investigations recently initiated by the Commission clamping down on EU states that grant sweetheart deals to . . .
The European Commission will publish this week the formal letter the Commission sent to Ireland in June setting out its preliminary view that Ireland violated state aid in granting private tax rulings to Apple . . .
The European Commission on September 28 published its annual overview of recent tax reforms . . .
Bermuda is seeking immediate removal the European Commission’s list of non-cooperative jurisdictions as both Latvia and Poland have now confirmed that they have taken Bermuda off their national tax blacklists. Poland and Latvia have contacted the European Commission to confirm Bermuda’s. . .
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
The European Commission will be giving up its state aid investigation into EU patent box regimes because its 2008 decision to approve Spain’s patent box created the expectation that the programs are legal, writes Victoria Slind-Flor of Boomberg, in a February 3 article, quoting a Commission official. See, Bloomberg.
The European Commission, in a July 24 website post, announced it has extended the deadline for submitting applications to serve as a VAT Expert Group member until Sept. 12. Website, Call for Applications (22KB), Prior coverage.
The European Commission on February 3 opened a state aid investigation into the private ruling practices of the Belgian tax administration. The rulings allow multinational entities in Belgium to reduce their corporate tax liability by “excess profits” that allegedly result from the advantage of being part . . .
The EU Council, on January 27, amended the EU parent-subsidiary directive, adding a new antiavoidance rule. The action follows up on a political agreement reached on December 9 to amend the directive. The directive exempts from taxation dividends and other profit distributions received by parent companies from subsidiaries located in different member states. The amended directive provides that tax exemptions for . . .
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
G20 finance ministers, in a communique released following their Sept. 20-21 meeting in Carins, Australia, have expressed approval of the progress made toward completion of the G20 OECD Base Erosion and Profit Shifting (BEPS) Action Plan and have committed to finalizing all action items by 2015. Further, the ministers endorsed the finalized global Common Reporting Standard for automatic exchange of tax information, committing to exchange of information by 2017 or end-2018, subject to the completion of legislative procedures. Communique. See also, G20 release, prior coverage of BEPS recommendations.
UK formally commits to country-by-country reporting template: The UK has agreed to implement the country-by-country reporting template provided for in the OECD/G20 BEPS recommendations, Financial Secretary to the Treasury David Gauke announced in a Sept. 20 release. See, UK release.
_____________
India disputes binding arbitration proposals in BEPS recommendations: In a Sept. 22 speech before the G20, India’s Minister of State for Finance expressed support for the OECD/G20 BEPS project but said that developing nations had “major concerns” with proposals to introduce binding arbitration into the mutual agreement procedure for tax treaties. See, speech of Smt. Nirmala Sitharaman, India Minister of State for Finance. See, related coverage.
_____________
The OECD and Global Forum announce mandate to assist developing nations with BEPS: The OECD and its Global Forum on Transparency and Exchange of Information announced on Sept. 22 that they have been mandated by the G20 to develop toolkits to support developing countries in addressing BEPS and to launch pilot projects to assist them to move towards automatic exchange of information. The OECD said it will report to the G20 Leaders in November on its plan to deepen the involvement of developing countries in the OECD/G20 BEPS project and ensure that their concerns are addressed. OECD release.
The European Court of Justice on February 3 ruled that a UK law that puts restrictions on the ability of group companies to offset gains with nonresident subsidiary losses is compatible with EU law, rejecting the European Commission’s claim that the law made it “virtually impossible” . . .
Advancing the common consolidated corporate tax base (CCCTB) proposal in Europe is a “high priority,” for new Commissioner for Economic Affairs, Pierre Moscovici. The CCCTB would shut off major channels of tax avoidance, ensuring a closer . . .
Luxembourg will provide the European Commission with a list of taxpayers that received private tax rulings in 2010–2012 involving cross-border dealings, as well as a list of the beneficiaries of its intellectual property regime, Prime Minister Xavier Bettel said December 18 . . .
The European Commission has been forced to delay decisions on whether countries violated state aid rules by granting private tax rulings to Amazon, Apple, Fiat, and Starbucks, EU competition commissioner, Margrethe Vestager, said May 5 . . .
German, French, and Italian finance ministers have asked the EU Commission to take immediate steps to more aggressively tackle corporate tax avoidance in the EU. In a letter addressed to European economy, finance and tax commissioner Pierre Moscovici . . .
European Commission President Jean Claude Juncker on November 12 said advance tax rulings issued by Luxembourg to multinationals while he was the country’s prime minister were legal even though the rulings helped multinationals avoid tax due other European nations. Juncker was responding the uproar over the release of leaked taxpayer private rulings and tax returns which were . . .
The European Commission on June 8 escalated its inquiry into whether EU countries’ tax ruling practices provide a selective advantage to companies in violation of state aid rules, asking 15 EU nations to provide the . . .
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
