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On December 30, 2015 the Dutch State Secretary for Finance issued a Decree containing further regulations regarding documentation obligations for multinationals with respect to transfer prices (Regeling aanvullende documentatieverplichtingen verrekenprijzen). The Decree exists out of 7 articles, 6 annexes and an explanation.
Article 6 of the Decree arranges that the Decree enters into force as per January 1, 2016 and that its provisions will for the first time apply to reportable years of multinational groups that start on or after January 1, 2016.
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On December 30, 2015 on the website of the Dutch Staatscourant the text of the Competent Authority Arrangement between the Competent Authorities of the United States of America and the Kingdom of theNetherlands was published. The Competent Authority Arrangement between the Competent Authorities of theUnited States of America and the Kingdom of theNetherlands was signed for the Netherlands Competent Authority October 28, 2015 and for the United States Competent Authority on November 30, 2015.
Read more: (FATCA) Competent Authority Arrangement between the Netherlands and the U.S. published
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On December 29, 2015 on the website of the Maltese Inland Revenue Guidelines for the implementation of the EU Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (DAC2) in Malta and the Common Reporting Standard (CRS) issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) were published. With 121 pages the document is extensive.
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On December 28, 2015 the Inland Authority of Singapore issued a press release that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital (Hereafter: the DTA) entered into force. The new DTA replace the existing/old Agreement stemming from 1993.
Read more: New Luxembourg – Singaporean DTA entered into force
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On December 9, 2015 we already reported on the policy paper titled: “Corporation Tax: anti-hybrid rules” that was published by the UK HM Revenue & Customs (HMRC) (read our article here). When publishing the policy paper the HMRC already announced that on December 22, 2015 it would publish a series of examples illustrating the application of the hybrid mismatch rules. And so it did.
On December 22, 2015 the HMRC published a document titled: “Draft Examples - Clause 33: Hybrid and other mismatches”. The document contains 20 examples that are ordered based on the subject they relate to.
Read more: HMRC publishes draft examples illustrating the application of the hybrid mismatch rules
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