OECD publishes Discussion Draft on cost contribution arrangements
On 29 April 2015, the OECD issued a Discussion Draft on the transfer pricing aspects of cost contribution arrangements (‘CCAs’) under Action 8 of the BEPS action plan. The Draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines: With respect to measuring the value of contributions to CCAs and the tax
Revised OECD BEPS timetable
The OECD has published a revised OECD timetable for stakeholders’ input, with the dates when new discussion drafts will be published and public consultations will be held in relation to the 2015 Base Erosion and Profit Shifting (BEPS) outputs. The revised OECD timetable can be consulted here. During March and April 2015, the OECD released
EC presents proposal for mandatory automatic exchange of information on cross-border tax rulings within the EU
In a press release of 18 March 2015, the European Commission (“EC”) announced its Tax Transparency Package, including a proposal to broaden the scope of the EU Council Directive (2011/16/EU) on Administrative Cooperation in the field of taxation (known as the “DAC”). Mandatory exchange of information The EC has released its proposed modification to the
Belgium-Luxembourg cross-border workers
Belgium-Luxembourg cross-border workers: mutual agreement signed and information regarding evidence to support presence in Luxembourg published Following the announcement made early February, the Belgian and Luxembourg finance ministers concluded on 16 March 2015 a mutual agreement with respect to cross-border employment tax situations that confirms, retroactively as from 1 January 2015, the introduction of a derogation to
European Commission announces investigation into Belgian excess profit ruling system
On 3 February 2015, the European Commission released a press release announcing an in-depth investigation into a Belgian tax provision that allows group companies to reduce their corporate tax basis with a profit part that results from the advantage of belonging to a multinational group, on the basis of what is referred to as an “excess profit” tax ruling. The press release
Facilitation for Belgium-Luxembourg cross-border workers
The Belgian and Luxembourg governments had a joint meeting yesterday in Brussels and came to the following agreement with respect to cross-border employment tax situations: With respect to wages taxes, a tolerance will retroactively (as from 1 January 2015) enter into force regarding the physical presence outside the (usual) country of employment. Concretely, a Belgian resident
EU PSD – Council adopts anti-abuse clause
In a press release of 27 January 2015, the Council has disclosed its amendments to the EU Parent-Subsidiary Directive (PSD) (2011/96/EU). Objective of the amendments The Council amended the PSD, adding a binding anti-abuse clause to prevent tax avoidance and aggressive tax planning by corporate groups. The aim is to stop the PSD from being misused for tax avoidance and to
UK’s ‘Diverted Profits Tax’ proposes a 25% tax rate for taxpayers but leaves open questions
Background On 10 December 2014 HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. Upon initial review, the new rules could affect many more companies than one might have anticipated. Scope The DPT is a new tax, with a 25% rate on profits that are considered
