On 26 February 2019, the Court of Justice of the European Union (CJEU) issued its judgments in T Denmark and Y Denmark vs. The Danish Ministry of Taxation (Joined Cases C-116/16 and C-117/16 – “the dividend cases”) and in N Luxembourg 1, X Denmark A/S, C Danmark I and Z Denmark ApS vs. the Danish
Anti-Tax Avoidance Directive Webcast Series Episode Two: Netherlands and Italy Thursday, 28 February 2019, 15:00 – 16:00 CET
We are pleased to inform you of the next episode of our Anti-Tax Avoidance Directive Webcast Series, Episode 2: Netherlands and Italy. The EU Anti-Tax Avoidance Directive (ATAD I & II “ATAD”) is designed to tackle tax avoidance practices, and creates minimum standards for EU Member States, which may require changes to corporate tax laws.
The evolution of the marketing mechanism is more and more sensitive, and it’s not always easy for non-marketers to propose strong content in an accurate structure, design it and follow-up under the business’ time constraints.
Carried forward tax losses of both the absorbed and absorbing company are subject to limitation upon a tax neutral merger. As regards tax losses of the absorbing company, it is generally accepted by tax practitioners that the loss limitation rule only applies to prior year tax losses (i.e. losses reported in the latest tax return
European Court annuls the decision of the European Commission that Excess Profit rulings are State Aid
The General Court decided that the European Commission has made an error in its decision where it concluded that the Belgian excess profit regime resulted in a so-called ‘State aid scheme’. As a result of this approach under a State aid scheme (rather than assessing each of the rulings involved), the European Commission limited its
Circular 2019/C/14 – Addendum to the circular 2017/C/56 containing additional guidance on the transfer pricing documentation penalty regime
On 8 February 2019, an addendum to the circular was issued containing additional guidance on the transfer pricing documentation penalty regime. General All companies and permanent establishments must prepare transfer pricing documentation unless they meet certain thresholds for exemption from filing documentation. Failing to file (in due time) the transfer pricing documentation (i.e. country-by-country report