PwC EUDTG Newsalert – 10 July 2020 (Non-confidential version of the EC’s State aid decision to extend proceedings in Inter IKEA)
On 2 July 2020, the public version of the State aid decision of the European Commission (EC) to extend the State aid investigation into the Netherlands’ tax treatment of Inter IKEA Systems BV (Systems) was made available. In its decision to extend proceedings, the EC preliminarily concludes that the contested measures (the 2006 and 2011
Spanish Central Administrative Tribunal‘s decision to apply the CJEU’s Danish cases to deny the withholding tax exemption on dividends
The Central Administrative Tribunal (i.e., administrative body) has recently published a ruling in which it applies the doctrine from the ECJ in the Danish cases to a Spanish case denying the withholding tax exemption on dividend payments to EU parent companies. For more information, please see enclosed PwC’s EU Direct Tax Group (EUDTG)’s Newsalert on:
Optional deferral of the reporting obligation – Germany opts out
The Council Directive (EU) 2020/876 of 24 June 2020, amended the DAC 6 Directive by deferring the reporting deadlines by 6 months. Since the deferral is included in the Directive, an implementation is required in order to be reflected in the domestic legislation of the different Member States. Given the optional character of the amendment
DAC 6 reporting deadlines deferred with 6 months
Due to the COVID-19 pandemic and by way of administrative tolerance, the Belgian government has granted a 6-month delay to fulfil the first reporting obligations under the DAC 6 legislation. The decision follows a European proposal for an amending council directive in this respect. In short, DAC 6 provides for the obligation to report certain
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
