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On May 16, 2017 the Japanese Ministry of Finance issued a press release announcing that the Government of Japan and the Government of the Republic of Iceland will initiate negotiations for a tax convention to be concluded between the two countries.
Read more: Japan – Iceland: Negotiations for a DTA will be initiated
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On May 15, 2017 the Dutch Minister of Finance sent an annotated agenda for the following Eurogroup and Economic and Financial Affairs (ECOFIN) Council to the Dutch House of Representatives. These meetings will take place on May 22, 2017 (Eurogroup) and on May 23, 2017 (ECOFIN Council). According to the annotated agenda several tax topics will be discussed during the ECOFIN Council of May 23, 2017.
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On April 21, 2014 the Dutch Supreme Court judged in several joined cases (ECLI:NL:HR:2017:638) of which the Advocate General stated in his opinion that they were a consequence of the incorrect judgment of the Court of Justice of the European Union in the Bosal case (Case C-168/01). The AG calls the contested tax planning structure a form exploiting a gap that was created by the aforementioned judgment of the CJEU
In the Bosal case the CJEU ruled that:
“Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, interpreted in the light of Article 52 of the EC Treaty (now, after amendment, Article 43 EC) precludes a national provision which, when determining the tax on the profits of a parent company established in one Member State, makes the deductibility of costs in connection with that company's holding in the capital of a subsidiary established in another Member State subject to the condition that such costs be indirectly instrumental in making profits which are taxable in the Member State where the parent company is established.”
In his opinion from August 25, 2016 the AG furthermore states that with its judgment the CJEU created a mismatch between exempted income from participations and the deductibility of costs that are directly attributable to that exempted income. According to the AG such fiscal coherence-distorting jurisprudence obviously entails constructions such as those that are contested in the underlying case.
Read more: Dutch Supreme Court rules that trading in tax capacity constitutes an abuse of law
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On May 15, 2017 the Japanese Ministry of Finance issued press releases announcing that it came to agreements in principle on Double Taxation Agreements to be concluded with Denmark and Japan.
Read more: Japan comes to agreements in principle on DTAs to be concluded with Denmark and Estonia
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On May 12, 2017 the OECD issued a press release announcing that Lebanon became the 89th signatory of the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA). According to the overview of Signatories of the MCAA, Lebanon intends its first exchange of information to take place in September 2018.
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