On December 13, 2016 the Competent Authorities of Singapore and Iceland concluded an Agreement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance (Hereafter: The Agreement).

Singapore and Iceland will commence the Automatic Exchange of Information under the CRS by September 2018. The first year for which information will be exchanged under the Agreement is 2017.

On December 14, 2016 a Government discussion document on measures to strengthen transfer pricing rules and prevent permanent establishment (PE) avoidance was published on the website of the New Zealand Inland Revenue. In this so-called cabinet paper the New Zealand cabinet states that it currently considers introducing a package containing certain features of a DPT and to combine them with the OECD’s BEPS measures and some domestic law amendments to produce a package that is tailored for the New Zealand environment.

On December 17, 2016 the OECD issued a press release announcing that on December 14, 2016 Monaco deposited its instrument of ratification for the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Monaco signed the Convention on October 13, 2014.

On December 14, 2016 the Court of Justice of the European Union (CJEU) judged in Case C-378/15, Mercedes Benz Italia SpA versus Agenzia delle Entrate Direzione Provinciale Roma 3  (ECLI:EU:C:2016:950).

This request for a preliminary ruling concerns the interpretation of Article 17(5) and Article 19 of Sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonisation of the laws of the Member States relating to turnover taxes — Common system of value added tax: uniform basis of assessment (OJ 1977 L 145, p. 1), in the version in force at the material time in the main proceedings (‘the Sixth Directive’).

 

The request has been made in the course of proceedings between Mercedes Benz Italia Spa (‘Mercedes Benz’) and the Agenzia delle Entrate Direzione Provinciale Roma 3 (Revenue Authority, Provincial Office, Rome 3; the ‘tax authority’), concerning value added tax (VAT) deductions made by Mercedes Benz in respect of the 2004 tax year.

On December 13, 2016 the HM Revenue & Customs (HMRC) announced that the Convention between the United Kingdom of Great Britain and Northern Ireland and the Oriental Republic of Uruguay for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, which was signed on February 24, 2016 (Hereafter: the DTA), entered into force on November 14, 2016.

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