OECD webcast of 15 December 2014: Impact on intercompany financing
Today, the OECD broadcasted a webcast on the progress of its BEPS Action Plan. The expectations of this webcast were very high as the OECD had previously announced it would publish relevant Discussion Drafts after the webcast, which potentially could have a serious impact on intercompany financing. While the OECD gave insights into some items, such as interest deduction
UK states that OECD agrees on substantial activity level required to benefit from preferential IP regimes
The Governments of Germany and the United Kingdom (UK) have, on 11 November 2014, shown their commitment to ensuring that the G20/OECD Base Erosion and Profit Shifting (BEPS) project is successfully concluded by the end of 2015. As such, they have issued a joint statement on 11 November, so as to take forward the pending
The end of the (financial) year is near: everything under control?
For most companies, December is the last month of their financial year, which makes it the ideal time to reflect whether or not the company is in control of its tax and accounting obligations. Things that cross our mind are, for example: a final possibility to make an advance tax payment in order to avoid
Proposed legislation for Italian Patent Box regime
In Italy the bill for the 2015 Stability Law will introduce a “Patent Box” regime for companies performing R&D activities, either directly or in cooperation with universities. Both Italian and foreign companies (through a PE) would be able to benefit from the reduced effective income tax rate on profits generated by R&D projects. The exemption (50%)
ESMA issues new enforcement priorities for 2014
The European Securities and Markets Authority (the ESMA) has published its European Common Enforcement Priorities (the Priorities) for 2014. These Priorities identify topics that the ESMA, together with European national enforcers, see as a key focus of their examinations of listed entities’ IFRS financial statements. The aim of the common enforcement priorities is to achieve a high
Belgian reporting obligation for payments to tax havens
Belgian requirements for payments to ‘tax havens’ As from 1 January 2010, companies subject to Belgian corporate income tax or Belgian non-resident corporate income tax are obliged to declare direct or indirect payments exceeding EUR 100,000 to recipients established in so-called ‘tax havens’. The reporting obligation applies to both cash payments and payments in kind.
OECD publishes PE discussion draft (artificial avoidance)
The OECD has published its discussion draft on the Preventing of Artificial Avoidance of permanent establishment (PE) Status. This publication follows the BEPS (Base Erosion and Profit Shifting) timeline. A fundamental change to the existing PE rules, with a potentially wide impact on many structures currently in use by MNCs, are proposed in the OECD
New liability of inter-municipal organisations to corporate income tax as from 2015
After several proposals already during its previous terms of office, the new Federal Government has approved the liability of inter-municipal organisations to corporate income tax as from 1st January 2015. According to our experience, transiting from the tax on corporate bodies to corporate income tax is a complex issue to manage since the tax legislation
