Europe
Dutch tax consolidation regime violates EU law, advocate general concludes
Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .
EU VAT proposals for e-books, reverse charge fail
The Council of European Union at a meeting today failed to reach agreement on proposals to reduce the VAT rate for electronic publications and temporarily apply a generalised reverse charge mechanism; the EU VAT e-commerce proposal was also discussed, writes Davide Anghileri of the University of Lausanne . . .
German related-party royalty proposal conflicts with BEPS agreement, OECD tax official says
Tax professional Ninja-Antonia Reggelin discusses a German parliamentary hearing, held Wednesday, where tax experts provided their views on a controversial proposal to deny tax deductions for some royalty payments made by multinationals to related companies. . .
Switzerland, Pakistan sign new tax treaty
Switzerland and Pakistan signed a tax treaty on March 21, Switzerland’s Federal Council . . .
UK budget 2017 tax proposals tweak rules on interest deductibility, loss relief, hybrid mismatches
Julian Feiner of Dentons, London, discusses the tax proposals in the UK budget, delivered today, which include proposed revisions to interest deductibility, loss relief, and hybrid mismatch rules . . .
EU Presidency releases plan to prevent multinational tax avoidance
The European Council on February 7 released the Maltese Presidency’s work plan regarding tax measures to prevent base erosion and profit shifting by multinationals, notes Davide Anghileri of the University of Lausanne . . .
New Belgian innovation income deduction regime adopted, qualifying IP rights include copyrighted software
Daniel Garabedian and Steven Peeters, of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss a Belgian law passed last week that modifies the tax incentives for multinational enterprises that derive income from intellectual property rights . . .
Singapore, Finland agree to automatic exchange of financial account information for tax purposes
Singapore and Finland on November 22 signed an agreement committing to begin automatic exchange of financial . . .
EU Commission publishes decision to open McDonald’s state aid case on tax ruling
The European Commission on June 7 published the non-confidential version of its decision to open a State aid investigation into whether a tax ruling granted by Luxembourg to McDonald’s may have granted . . .
EU Commission paper addresses application of State aid rules to tax laws, rulings, and settlements
The EU Commission has issued a paper outlining its position on when a Member State’s laws and practices run afoul of EU restrictions on State aid, including when national tax laws, tax rulings, and tax settlements . . .
Ireland-Estonia treaty now exempts some royalty payments from tax
The tax treatment of royalty payments under the Ireland-Estonia tax treaty has been revised on account of the treaty’s most favored nation clause, Irish . . .
EU court asked if Dutch can deny foreign fund dividend withholding tax refund
The Dutch Supreme Court has asked the Court of Justice of the European Union to resolve two separate disputes concerning whether the Netherlands can deny foreign investment funds refunds of the Dutch dividend withholding . . .