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
Belgian Net Asset Tax compatible with EU law
The Court of Justice of the European Union (CJEU) ruled on 26 May 2016 that the Belgian Net Asset Tax (NAT) as applicable to foreign investment funds, is compatible with EU law. The CJEU’s decision in Case 48/15 (SPF Finances v. ING International SA) is rendered in the framework of a request for a preliminary
Cayman Tax: applicable to privately managed funds
Yesterday, the Finance Minister clarified the scope of the Cayman tax with respect to funds. According to the Minister, the tax covers private, institutional and public funds, which are de facto privately managed. Besides, should it prove necessary to legislate further, that would be done quickly and efficiently, according to the Minister. The Cayman Tax
New single annual bank tax announced
On Friday the 13th, the Council of Ministers approved a draft bill of law establishing a new single annual bank tax replacing four different existing taxes, with a view to a better distribution of the tax burden between small and large banks. Overall, it leads to a tax increase of EUR 55 million. As a
