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
Enhanced transparency for multinational enterprises: 44 tax administrations agree on CbCR and CRS information sharing system
During the 10th meeting of the OECD Forum on Tax Administration (FTA), held on 11, 12 and 13 May 2016, the heads of 44 tax administrations came to an agreement on the creation of a system that will enable the effective and efficient sharing of data gathered from the automatic exchange of information under the
European Commission proposes public Country-by-Country Reporting (CbCR) rules for EU multinational enterprises
On 12 April 2016, the European Commission (EC) introduced a legislative proposal on public reporting requirements for certain EU enterprises, being multinational groups with a consolidated turnover exceeding EUR 750 million. The proposal is founded on the EC’s determination to address corporate tax avoidance in Europe, of which the cost for the EU Member States
