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

Dutch Government sent a legislative proposal tightening the interest limitation rule to Parliament for approval
Irish Ministry of Finance publishes the responses it received on its public consultation on the OECD’s Two-Pillar Solution
OECD – Documents released with respect to the October 13th G20 Finance Ministers and Central Bank Governors Meeting
CJEU judges in the joined Cases C‑45/20 and C‑46/20, Finanzamt N (Communication de l’affectation) (VAT – Germany – Allocation to private assets is assumed or presumed in the absence of (sufficient) evidence of allocation to the assets of the business)
Advocate General: “The Parent-Subsidiary Directive (Directive 90/435/EEC) does not preclude a system of advance payments and tax credits at the time of redistribution of dividends”
The Dutch Government opened a public consultation on a legislative proposal to implement Council Directive (EU) 2021/514 (DAC7)
The OECD released an updated Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy together with a detailed implementation plan
Conclusie van de AG mbt de crisisheffing - Management beloning - Eigen loonverstrekking of loon van derden - Andere concern-maatschappij
Ireland to join the OECD agreement to address the tax challenges arising from the digitalisation of the economy
European Parliament adopts a resolution on reforming the EU policy on harmful tax practices (including the reform of the Code of Conduct Group)
The Government of the Hong Kong Special Administrative Region responds to the inclusion of Hong Kong in the EU's watchlist on tax co-operation
CJEU - The Advocate General is of the opinion that Finnish tax legislation with respect to open-ended investment funds is in breach with the right of free movement of capital
CJEU upholds the classification of the Spanish tax rules on the amortisation of financial goodwill as State aid incompatible with the internal market
Belastingen van rechtsverkeer - Moeten 2 in 1 akte geregelde afsplitsingen als één geheel worden beschouwd, of moeten beide afsplitsingen afzonderlijk worden getoetst aan de voorwaarden voor de splitsingsvrijstelling?