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On the website of the European Council/Council of the European Union a Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) and Explanatory Notes have been released to the public.
On December 7, 2015 we already reported on the ECOFIN meeting that would take place on December 8, 2015. In this article we included links to the documents for this meeting that were available on the website of the European Council/Council of the European Union. At that time on the website of the European Council/Council of the European Union a link to a Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) was shown. However when clicking on the link one was told that the document was not available for the public. Now however it became available to the public and so did the relating Explanatory Notes.
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On November 26 and November 30 we already reported that the European Parliament’s Special Committee on Tax Rulings and Other Measures Similar in Nature or Effect (TAXE) published written replies it received from 10 multinationals that were present during TAXE’s November 16th meeting. On December 14, 2015 TAXE (I) published the written reply it received from IKEA GROUP.
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On December 15, 2015 the OECD issued a press release announcing that on that same date Monaco signed the Multilateral Competent Authority Agreement (MCAA), bringing the total number of signatories to 76. According to the overview of Signatories of the MCAA and the intended first information exchange date, Monaco intends its first exchange of information to take place in September 2018.
Read more: Monaco signs the Multilateral Competent Authority Agreement
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On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation.
According to the media release the detailed rules mean that the practical arrangements are now in place for the entry into application of the amended Directive on Administrative Cooperation (Council Directive 2011/16/EU) from January 1, 2016.
Read more: European Commission adopts new rules to help EU tax authorities exchange information
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The Australian Taxation Office (ATO) has released a Taxpayer alert on arrangements involving the use of offshore entities which source goods (procurement hub) on behalf of Australian resident multi-national enterprises (MNEs) (TA 2015/5).
In the alert the ATO announces that it is currently reviewing arrangements involving the use of offshore entities which source goods (procurement hub) on behalf of MNEs. In these arrangements the procurement hub receives services from a related offshore entity (services hub). The ATO states that it concerns about these arrangements primarily relate to the application of the controlled foreign company (CFC) rules, the transfer pricing rules and Part IVA of the Income Tax Assessment Act 1936 (ITAA 1936) (General Anti-Avoidance Rules).
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