OECD releases request for input on BEPS Action 11
Background The Action 11 work of the BEPS (base erosion and profit shifting) action plan aims to produce an overview of several different economic analyses of BEPS using different data and methodologies that will give a potential range of the scale (i.e. magnitude of the change in overall tax receipts) and economic impacts (i.e. effects on total
OECD releases global standard for automatic exchange of tax information
Starting in 2012, political interest has increasingly focused on the opportunities provided by an automatic exchange of information between tax authorities. On 6 September 2013, the G20 Leaders committed to the automatic exchange of information as the new global standard and fully supported the OECD work for developing a single standard for automatic exchange of
OECD Publishes 2014 Update to Model Tax Convention
The OECD Council approved the 2014 Update to the OECD Model Tax Convention (the 2014 Update) on 15 July 2014. The 2014 Update was already approved by the Committee on Fiscal Affairs on 26 June 2014. The 2014 Update can be found here. The 2014 Update mainly reflects the work that was carried out by the OECD
Update: Member States agree to amend Parent-Subsidiary Directive
The European Union’s (EU) 28 Finance Ministers agreed, on June 20, 2014, to amend the EU’s Parent –Subsidiary Directive (Directive), addressing the effects of tax arbitrage resulting from EU Member States’ varying tax treatments of hybrid loans. The Member States have agreed that the Directive’s benefits should not result in ‘double non-taxation,’ that is, income going untaxed
Belgian corporate tax deduction rejected for stock option plan cost recharged by foreign parent company
Court of Appeal of Brussels confirms four-year old decision of Court of First Instance of Brussels. We refer to our HRS Headline of 26 May 2010. On 25 June 2014, the Court of Appeal of Brussels confirmed the decision of the Court of First Instance of Brussels of 16 April 2010. According to this decision,
Danish National Tax Tribunal publishes its first decision regarding a cash pool arrangement
In early 2014,the National Tax Tribunal (Landsskatteretten) published its first transfer pricing decision regarding a cash pool arrangement. The decision concerns the determination of intercompany interest rates on deposits and borrowings in the cash pool. The National Tax Tribunal ruled that the Danish tax authorities were allowed to disregard the transfer pricing applied by the
EU Member States agree to amend the EU PSD to tackle hybrid loan arrangements
On 20 June 2014, the EU’s Council of Economic and Finance (ECOFIN) Ministers took place in Luxembourg. ECOFIN agreed amongst others on the amendments to the Parent-Subsidiary directive (PSD) and adopted conclusions on the report of the Code of Conduct Group on Business Taxation. Proposed amendments on the Parent – Subsidiary directive The ECOFIN agreed
Formal EU State Aid investigation into certain tax rulings
On June 11, 2014, the European Commission opened a formal State Aid investigation procedure into the transfer pricing arrangements and corporate taxation of certain companies in Ireland, the Netherlands and Luxembourg. See this link for more information. Wider inquiry into tax rulings In parallel to these three formal investigations, the Commission will continue its wider inquiry
