European Commission adopts temporary State aid framework enabling EU Member States to support their economies during the COVID-19 crisis
The European Commission adopted a temporary framework setting out the possibilities for EU Member States to support the economy during the COVID-19 crisis on 19 March 2020 under the European State aid rules. Such framework set outs the possibilities under which EU Member States can enact legislation and take actions to provide state support to
Important changes regarding the Polish DAC6 Mandatory Disclosure Rules
Our Polish DAC 6 experts informed us that the Polish parliament is processing a draft act amending the mandatory disclosure rules (MDR) as implemented following the European DAC6 Directive. The draft aims to introduce important changes to MDR reporting obligations, in particular relating to cross-border tax schemes. Highlights The Minister of Finance stated that the
CJEU rules that Belgian participation exemption infringes Parent-Subsidiary Directive
On 19 December 2019, the Court of Justice of the European Union (CJEU) rendered its judgment in the “Brussels Securities” case. The CJEU ruled that the combination of the dividends-received deduction and the order of deductions as arranged in the Belgian corporate income tax system infringes the Parent-Subsidiary Directive. What is the issue? In
Mandatory disclosure rules for intermediaries (DAC 6) – Belgian law adopted by the Chamber of Representatives
On 12 December, the draft bill implementing the EU Council Directive 2018/822/EU of 26 May 2018, also known as “DAC6 Directive”, has been adopted by the Chamber of Representatives. In short, DAC6 provides for the obligation to declare certain cross-border tax arrangements to the Belgian tax authorities. This obligation is incumbent on both taxpayers
UK publishes draft legislation and guidance on digital services tax
The UK tax authorities on July 11 published draft legislation and draft guidance for a digital services tax (DST) to become effective April 1, 2020. These are available for public consultation until September 5, 2019. The DST is expected to apply by default at 2% of deemed UK revenues derived in excess of £25m, where
CJEU judgments on Swedish “final losses” cases
On 19 June 2019, the Court of Justice of the European Union (CJEU) issued its judgments in Memira Holding (C-607/17) and Holmen (C-608/17) on Swedish “final tax” losses. A brief explanation of the decision can be found via this link.
European Commission announces final State aid decision on financing income exemption within the UK’s CFC rules
On 2 April 2019, the European Commission (EC) announced that the Group Financing Exemption (GFE) within the UK Controlled Foreign Company (CFC) rules is “partly justified”. The decision has not yet been published but a brief explanation of the decision can be found via this link.
European Commission opens State aid investigation into Luxembourg’s tax treatment of Huhtamäki
On 7 March 2019, the European Commission (EC) announced the opening of an in-depth State aid investigation in a number of tax rulings granted by Luxembourg to Huhtamäki. This decision is another important decision in a range of decisions dealing with the taxation of intra-group financing activities. A brief explanation of the decision can be found
