On 10 October 2017, the ECOFIN Council formally adopted a Directive on tax dispute resolution mechanisms in the EU. The objective is to establish more effective and efficient procedures within the EU. The Directive builds on the existing Convention 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated
On October 4, 2017, the European Commission (EC) continued its ongoing challenges to Member States’ transfer pricing tax regimes by advancing two high profile cases to the next stages. In the Apple case, the EC referred Ireland to the Court of Justice of the European Union (CJEU) for failing to enforce an August 2016 State aid recovery decision,
According to the Swiss Federal Department of Finance the additional protocol to the Double Tax Treaty (‘DTT’) between Belgium and Switzerland, that has been signed on April 10, 2014 has entered into force as of July 19, 2017 and will generally apply as from January 2018. In general terms, the protocol brings the current DTT,
On 26 July 2017, the federal government reached an agreement on an important tax, economic and social reform package. A significant gradual reduction in the corporate income tax rate to 25% in 2020 and fiscal consolidation are key components of the package. The agreement preserves the notional interest deduction. The tax reform is built around
Remark: The following announced measures will have to be formalised in draft legislation which should only be available as from September/October. Only then will full details be known. On 26 July 2017, the Federal government reached an agreement on an important corporate tax reform, significantly reducing the corporate tax rate. More details will follow below.
2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
On 10 July 2017, the Organisation for Economic Cooperation and Development (OECD) announced that it released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). The 2017 edition is a consolidated version of the various changes resulting from the OECD/G20 BEPS Project. In this respect, in particular the following