Tax on conversion of bearer stocks – Infringement of EU Law
On 9 October 2014, the Court of Justice of the European Union (below ‘CJEU’) has rendered its decision in case C-299/13 relating to the compatibility of the Belgian tax on the conversion of bearer securities with EU law, and in particular with Directive 2008/7/EC of 12 February 2008 concerning indirect taxes on the raising of
ESMA Q&A – FSMA position papers – latest developments
The European Securities and Markets Authority (below ‘ESMA’) promotes common supervisory approaches and practices in respect of the application of the European Directive on Alternative Investment Fund Managers (below the ‘AIFMD’) and its implementing measures. In this context, ESMA has publishedQuestions & Answers (below ‘Q&A’) on the application of the AIFMD. These Q&A have been
Corporate income tax returns: extension of the filing deadline
Due to some technical maintenance on the server of the Belgian tax authorities, the electronic filing of the tax returns was not possible during the weekend. The Belgian tax authorities therefore decided to extend the filing deadline to Friday 3 October 2014 midnight.
OECD Report on Action 6 – Treaty Abuse
The OECD published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where the abuse involves application of treaty benefits. It also proposed a
OECD guidance on Transfer Pricing Aspects of Intangibles: Revised Chapters I, II and VI of the OECD Transfer Pricing Guidelines
On 16 September 2014, the OECD published its final and interim revisions in relation to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These revisions have been developed in connection with Action 8 of the Action Plan on Base Erosion and Profit Shifting that is focused
OECD finalises guidance on transfer pricing documentation and country-by-country reporting
On 16 September 2014, the Organisation for Economic Cooperation and Development (OECD) finalized its guidance in relation to transfer pricing documentation and country-by-country (CbC) reporting. The final report is broadly consistent with the Discussion Draft released by the OECD on 30 January 2014, although it has pared back some proposals in response to concerns of
OECD recommendations on BEPS 2014 deliverables: Few surprises, but no let-up
As indicated in a newspost earlier this week, the BEPS deliverables for the September 2014 deadline have been published on 16 September 2014 and are available on the OECD website. Please find herewith a link to a summary PwC Bulletin in this respect, highlighting the key take-aways of the reports.
OECD releases BEPS reports following September deadline
The OECD is keeping its word in preparing and delivering on the objectives as they have been set in the BEPS Action Plan. The deliverables for the September 2014 deadline have just been published and are available on the OECD website (link below). The OECD has published 7 reports (Digital Economy, Hybrid Mismatches, Harmful Tax, Treaty Abuse, Intangibles
