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Published: 28 February 2015

(February 28, 2015) 

On February 27, 2015 the UK HM Revenue & Customs issued a press release announcing that on February 26, 2015 the United Kingdom of Great Britain and Northern Ireland and the Republic of Senegal signed a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion and Tax Fraud with respect to Taxes on Income and on Capital Gains (Hereafter: DTA). Although the DTA has been signed, it has not yet entered into force. The DTA will enter into force once both countries have completed their respective ratification procedures.

·        Under the DTA dividend withholding taxes are limited to 5% of the gross amount of the dividends in case of qualifying shareholdings (at least 25 percent of the capital of the company paying the dividends), to 8% of the gross amount of the dividends if the beneficial owner is a pension scheme and to 10% of the gross amount of the dividends in all other cases;

·        Under the DTA interest withholding taxes are limited to 10% of the gross amount of the interest;

·        Under the DTA royalty withholding taxes are limited to 10% of 60% of payments of any kind received as a consideration for the use of, or the right to use, industrial, commercial or scientific equipment and to 10% of the gross amount of the royalties in other cases;

Read more: United Kingdom and Senegal sign DTA

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Published: 27 February 2015

(February 27, 2015) 

On February 27, 2015 the Belgian Ministry of Finance issued a press release by which it announced that the Convention between the Kingdom of Belgium and the Kingdom of Bahrain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital (Hereafter: DTA) entered into force on December 11, 2014. At the same date also the Protocol (Hereafter: Protocol) amending the DTA, entered into force.

Based on Article 30 of the DTA the fact that the DTA entered into force on December 11, 2014 means that the provisions of the Convention shall have effect: 

a)     with respect to taxes due at source on income credited or payable on or after January 1, 2015;

b)     with respect to other taxes charged on income of taxable periods beginning on or after January 1, 2015;

c)     with respect to taxes on capital charged on elements of capital existing on or after January 1, 2015.

Read more: DTA between Belgium and Bahrain entered into force

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Published: 26 February 2015

(February 26, 2015) 

On February 26, 2015 the opinion of Advocate General Jääskinen in Case C-657/13, Verder LabTec GmbH & Co. KG versus Finanzamt Hilden (ECLI:EU:C:2015:132) was published on the website of the European Court of Justice (CJEU).

The following question was referred to the CJEU for a preliminary ruling:

Is it consistent with the freedom of establishment under Article 49 of the Treaty on the Functioning of the European Union if, upon the transfer of an asset from a domestic to a foreign permanent establishment of the same undertaking, a national rule stipulates that there is a withdrawal for non-business purposes, with the result that the disclosure of hidden reserves leads to a profit upon the withdrawal, and another national rule provides the possibility of spreading that profit equally over 5 or 10 financial years?

Read more: Opinion of Advocate General Jääskinen delivered in Case C-657/13, Verder LabTec (Freedom of...

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Published: 26 February 2015

(February 26, 2015) 

On February 26, 2015 the Government of Liechtenstein issued a press release announcing that on February 26, 2015 the Government of the Italian Republic and the Government of the Principality of Liechtenstein signed an Agreement on the Exchange of Information on Tax Matters (TIEA). Although the Agreement has been signed, it has not yet entered into force. The Agreement will enter into force once both countries have completed their ratification procedures.

Read more: Italy and Liechtenstein sign Agreement on the Exchange of Information on Tax Matters