News archive September 2014

List of articles in category News archive September 2014
Title
State aid: European Commission publishes non-confidential versions of decisions to open investigations into transfer pricing arrangements on corporate taxation of Apple (Ireland) and Fiat Finance and Trade (Luxembourg)
FATCA agreement between Brazil and the U.S. signed
Ireland – Statement in relation to EU State Aid investigations published on the website of the Irish Department of Finance
UK – HMRC releases Revenue and Customs Brief 32 (2014): VAT - policy on holding companies
Liechtenstein and the Czech Republic have signed a DTA
Canada and New Zealand have signed a Second Protocol to their existing DTA
The U.S. Department of the Treasury and the Internal Revenue Service issue a Notice announcing their intention to issue regulations to Reduce Tax Benefits of Corporate Inversions
OECD releases Report on the Impact of Base Erosion and Profit Shifting in Low Income Countries (Part 2) and a Roadmap for developing country participation in the new global standard for the automatic exchange of information between jurisdictions
Singaporean government opens a consultation on proposed regulations to help financial institutions comply with U.S. FATCA
BEPS - G20 endorses the finalised global Common Reporting Standard for automatic exchange of tax information on a reciprocal basis

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INTERESTING ARTICLES

Strike 1 - CJEU annuls the European Commission’s decision that the Belgian system relating to the excess profit of multinational companies constituted an aid scheme
CJEU judges in Case C-562/17, Nestrade (VAT – VAT refund sought by an undertaking not established in the EU)
CJEU judges in Case C-531/17, Vetsch Int. Transporte (VAT – Intra-community transfer – Acquirer committing tax evasion with a subsequent taxable transaction)
Guernsey deposits its instrument of ratification for the MLI
Mauritania signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters
Armenia joined the Inclusive Framework on BEPS
Ireland deposits its instrument of ratification for the MLI
CJEU judges in Case C-165/17 Morgan Stanley & Co International (VAT – Deduction of input tax – Goods and services used for both taxable transactions and exempt transactions (mixed-use goods and services))
Panama has signed the MCAA on the Exchange of Country-by-Country Reports
Papua New Guinea signs the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI)
The opinion of the AG in Case C-133/18, Sea Chefs Cruise Services (VAT – Interpretation of Article 20(2) of Council Directive 2008/9/EC of 12 February 2008)
CJEU judges in Case C-410/17, A (VAT – Do the services carried out constitute one single transaction or do they comprise two transactions?)
The opinion of the AG in Case C-607/17, Memira Holding (Freedom of establishment – Deduction of losses of a foreign subsidiary in the State of the parent company in the context of a merger)
The opinion of the AG in Case C-608/17, Holmen (Freedom of establishment – Deduction of losses in a subsidiary in another Member State)