ATAD: what does it actually mean for financing?
On 21 June, the Economic and Financial Affairs Council (ECOFIN) reached a consensus on the “Anti-Tax Avoidance Directive” (ATAD). Some of the measures of this Directive directly affect groups’ existing financing set-ups. The main impact is the implementation of BEPS Action 4 via a Directive, which will impose a general interest deduction limitation. Member States
ECOFIN agrees on Commission’s proposal on Anti-Tax Avoidance Directive
On 20 June 2016, the Economic and Financial Affairs (ECOFIN) Council agreed on the Anti-Tax Avoidance Directive (ATAD) proposal of the European Commission, following approval of the Dutch presidency’s final proposal by the Belgian government and no further comments from other Member States. On 8 June 2016, the European Parliament (EP) approved 91 amendments to
UK’s EU Referendum vote: PwC webcast – Friday, June 24
This week, the UK will vote to either leave or remain in the European Union (also known as “Brexit”). Regardless of the outcome of the UK’s EU referendum, there will be consequences for the European economy and business in general. To ensure our clients understand these issues, PwC will host a webcast examining the issues,
European Parliament approves amended Anti-Tax Avoidance Directive
On 8 June 2016, the European Parliament (EP) approved 91 amendments to a draft report of the Anti-Tax Avoidance Directive. The amendments to the draft Anti-Tax Avoidance Directive include, amongst others, proposals for a 15% rate for the application of the switch-over rule, an EU blacklist of tax havens and sanctions against uncooperative jurisdictions, additional limitations
Belgian transfer pricing documentation requirements submitted to Parliament
On 2 June 2016, the Belgian Government introduced in Parliament a draft Program Act containing the blue-print of how Belgium aims to implement the outcome of the OECD’s BEPS Action 13 into Belgian tax law. In essence, Belgium will introduce formal transfer pricing documentation requirements thereby requiring multinational entities (MNEs) with operations in Belgium – subject to certain conditions
OECD releases public discussion draft on the multilateral instrument to implement the tax treaty related BEPS measures and asks the public for input
On 31 May 2016, the OECD released its public discussion draft on Action 15 (Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures) of the BEPS Action Plan. Action 15 of the OECD’s BEPS Action Plan called for the development of a multilateral instrument in order to allow countries to swiftly amend their
Country-by-Country Reporting approved, Anti-Tax Avoidance Directive vote postponed
On 25 May 2016, the EU Economic and Financial Affairs Council (ECOFIN) approved the implementation of the Country-by-Country Reporting (CbCR) rules for multinational companies. However, the vote on the Anti-Tax Avoidance Directive (ATAD) proposal of the European Commission was postponed to the next council’s meeting, taking place on 17 June 2016. The directive implementing the
Preparing your business for imminent new reporting obligations
Belgian entities of foreign- or Belgian-headquartered multinational groups with annual revenues exceeding 50 million euros need to assess whether they will be subject to the transfer pricing documentation obligations that will be introduced soon. Given the increased scrutiny, it’s also imperative to check the consistency of transfer pricing arrangements with actual conduct. Three layers of
