News Europe
Dutch Government Issues A Decree On New Ruling Practice
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April 25th, 2019
The Secretary of State for Finance published a proposed Decree on the new Dutch international ruling practice. The decree contains guideline on the procedure for obtaining rulings, the content as well as transparency considerations.
Dutch Government To Change The Rules Governing Corporate Losses
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April 23rd, 2019
The Dutch government has launched a draft bill on corporate loss. The draft bill is aimed at preventing misuse of the liquidation and cessation loss rules and at expanding the tax base.
Google’s Ireland Tax Deal Draws EU Concerns
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April 19th, 2019
Google’s Irish operations are coming under closer scrutiny from Europe over corporate tax affairs. The European Union has taken a closer look at how Google uses operations in Ireland to help reduce its corporate tax obligations within the trade bloc.
German Ministry Of Finance Issues Draft Bill On Tax Dispute Resolution Mechanisms In EU
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April 19th, 2019
Germany's Ministry of Finance has published the draft law for the transposition of Council Directive (EU) 2017/1852.
Background
Dutch Government To Start A Series Of Investigations To Improve The Tax System
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April 16th, 2019
The Dutch government will start a series of new investigations to improve the tax system. The investigation will reassess the tax system that will examine the current tax mix and its distributive effects, taxation of income from digital sources, and the future of corporate taxation.
Turkey To Gradually Lower Corporate Tax Rate Under Its New Set Of Tax Reforms
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April 11th, 2019
Turkey’s Treasury and Finance Minister Berat Albayrak announced a new economic reform package. It includes significant changes in the tax regime, financial structure, agricultural policies and capital markets.
Dutch Parliament Vigorously Insists Shell Attends Tax Avoidance Hearing
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April 11th, 2019
The Dutch parliament will insist on Shell sending a representative to attend a hearing on tax avoidance by multinationals. The warning is given as Shell’s Dutch Chief Executive had previously declined the invitation.
European Tax Advisers Support EU Court’s Transfer Pricing Ruling
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April 10th, 2019
The European Union’s top court provided “an important clarification” on the conditional compatibility of domestic and bloc wide law when it ruled that Germany must allow multinational companies to justify their transfer pricing arrangements.
The Ruling .
European Commission Finds UK CFC Law Partially Granted State Aid
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April 5th, 2019
On 2 April 2019, the European Commission announced its decision that the group financing exemption allowed under the UK's controlled foreign company (CFC) Rules gave an illegal tax advantage to certain multinationals, constituting illegal State aid.
UK CFC Rules .
The Netherlands On Board To Adopt Minimum Tax By Introducing Conditional Withholding Tax Payments
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March 28th, 2019
Similar to Germany, the Netherlands will introduce a minimum tax by applying a conditional withholding tax on payments to low tax jurisdictions. The Netherlands and Germanu agreed, by issuing a joint statement, to back global efforts to revamp international tax rules for the digital era, as part of efforts by the Dutch government to clean up its reputation as a major enabler of corporate tax avoidance.
EU Parliament Adopts Countermeasures Against Tax Avoidance And Evasion
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March 28th, 2019
The European Parliament announced the adoption in a plenary vote of a resolution to approve the final report from the special committee on financial crimes, tax evasion and tax avoidance (TAX3), including the report's recommendations. The report takes controversial positions, including calling out seven member states for their role in facilitating aggressive tax planning and recommending countermeasures against the US should it fail to provide Foreign Account Tax Compliance Act (FATCA) reciprocity.
Belgium Publishes Legislation Implementing New Interest Deduction Restriction And Exchange Of Information With Third Countries
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March 26th, 2019
Belgium published in the Official Gazette the Law of 11 February 2019 on Fiscal, Anti-abuse, Financial, and Miscellaneous Provisions. Two of the key measures of the Law, which was approved by the parliament, are the implementation of the country's 30% of EBITDA interest deduction restriction and the exchange of information with third countries.
UK Issues Tax Guidance On No-Deal Brexit Scenario For Interest, Royalty, And Dividend
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March 21st, 2019
The EU Interest and Royalties Directive (IRD) and Parents Subsidiary Directive (PSD) allow EU companies to make certain interest and royalties payments to associated companies and permanent establishments within the EU without needing to deduct tax from them. However, if the UK leaves the EU without a deal on 29 March 2019, these directives will no longer apply to the UK.
EU Report: The Implementation Of CCCTB Might Reduce The Effective Tax Burden
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March 19th, 2019
The European Commission published Taxation Paper No. 75 related to Common Consolidated Corporate Tax Base (CCCTB), which aims at evaluating the impact of the CCTB on the effective corporate tax burdens in the 28 EU Member States and assessing the relative importance of single elements of the harmonized tax base.
EU Joint Transfer Pricing Forum To Continue Profit-Split Work
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March 19th, 2019
In light of the profit-split method’s potentially expanded role under a new regime for taxing the digital economy, the EU Joint Transfer Pricing Forum (JTPF) will explore ways to improve the method’s clarity and simplicity. As complementary to the OECD guidance, the report highlights two important parts, justification in applying Profit Split Method) PSM and the key allocation that can be used to split the profit.
EU Economic And Financial Affairs Council Decides To Add Ten Additional Jurisdictions To Non-Cooperative List
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March 14th, 2019
The EU Economic and Financial Affairs Council has issued a release on the main results from its 12 March 2019 meeting, including that it has adopted a revised list of non-cooperative jurisdictions for tax purposes. In addition to the five jurisdictions that were already listed, American Samoa, Guam, Samoa, Trinidad and Tobago and the U.
Dutch Government Issues Draft Decree On Transitional Tax Rules In The Case Of No-Deal Brexit
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March 14th, 2019
The Dutch State Secretary for Finance sent a draft decree containing a temporary transitional regime applying in the event of a "no-deal" Brexit to the lower house of the Parliament.
Background .
The Netherlands Updates Decree On Application Of Participation Exemption
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March 12th, 2019
The Dutch government updated Decree on the application of the participation exemption (the Decree) with effect from 9 March 2019, having retroactive effect to 13 February 2019. The clarification and amendments of the Decree relates to the application of option rights and simplification of dissolution procedure to the extent the subsidiary has been declared bankrupt or the decision to liquidate the holding has been taken, yet the liquidation has not been completed.
European Commission Warns Spain And Finland To Amend Their Discriminative Tax Policies
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March 12th, 2019
The European Commission published its Infringement Package for March 2019, which includes the infringement in the taxation area. In response to that, the European Commission sent a letter to Spain to eliminate discrimination on capital gains taxation and to Finland to bring its rules on tax deductibility of group contributions in line with EU law.
Spain And The UK Sign Tax Agreement On Gibraltar To Combat Tax Fraud And Money Laundering
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March 7th, 2019
Spain's Ministry of Foreign Affairs, the European Union, and Cooperation has announced the signing of a tax agreement with the UK concerning Gibraltar. The agreement is designed to combat tax fraud and money laundering in Gibraltar once the UK leaves the European Union and includes new rules on tax residency for both individuals and companies.

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