On December 9, 2016 the Government of the Hong Kong Special Administrative Region announced that the Agreement between the Hong Kong Special Administrative Region of the People’s Republic of China and Romania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, which was signed on November 18, 2015 (Hereafter: the DTA), entered into force on November 21, 2016.

On December 9, 2016 the Australian Taxation Office (ATO) published the 2014-15 Report of Entity Tax Information. According to the ATO the report contains some tax information for 1904 companies.

On December 9, 2016 the Japanese Ministry of Finance released the Notes that the Government of Japan and the Swiss Federal Council exchanged concerning the automatic exchange of information under the Convention on Mutual Administrative Assistance in Tax Matters.

The Exchange of Notes is intended to ensure that Japan and Switzerland will be able to commence the automatic exchange of financial account information related to taxable periods or charges to tax beginning on or after 1 January 2017 from 2018 in accordance with the Common Reporting Standard established by the OECD, as is already confirmed by the Joint Statement between the two Governments signed last January (See our article from January 29, 2016).

The Competent Authorities of Singapore and The Netherlands concluded an Agreement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance (Hereafter: The Agreement).

On December 8, 2016 the European Commission issued a press release announcing that it referred FRANCE to the Court of Justice of the European Union for discrimination in the taxation of dividends.

The dispute concerns the refund of tax paid in France by companies with subsidiaries in other countries of the European Union (under the ‘advance payment of tax' mechanism). Although the Council of State had referred questions for preliminary ruling to the Court, it then adopted a restrictive interpretation of the CJEU judgment in two judgments handed down in December 2012. The Commission takes the view that those judgments are incompatible with EU law.

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