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On June 21, 2018 the OECD released Revised Guidance on the Application of the Transactional Profit Split Method (BEPS Action 10). The revised guidance, while not being prescriptive, clarifies and significantly expands the guidance on when a profit split method may be the most appropriate method.
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On June 21, 2018 the OECD released Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles (BEPS Action 8). The guidance contained in the report aims at reaching a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of the Hard-to-Value Intangibles (HVTI) approach. The guidance should improve consistency and reduce the risk of economic double taxation.
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On June 21, 2018 the Court of Justice of the European Union (CJEU) judged in Case C-480/16, Fidelity Funds, Fidelity Investment Funds, Fidelity Institutional Funds versus Skatteministere (ECLI:EU:C:2018:480).
This request for a preliminary ruling concerns the interpretation of Articles 56 and 63 TFEU.
The request has been made in proceedings brought by Fidelity Funds, Fidelity Investment Funds and Fidelity Institutional Funds against the Skatteministeriet (Ministry of Taxation, Denmark), concerning claims for repayment of withholding tax levied on dividends paid to them by companies resident in Denmark between 2000 and 2009.
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On June 20, 2018 the Court of Justice of the European Union (CJEU) judged in Case C-108/17, UAB ‘Enteco Baltic’ versus Muitinės departamentas prie Lietuvos Respublikos finansų ministerijos, intervener: Vilniaus teritorinė muitinė (ECLI:EU:C:2018:473).
This request for a preliminary ruling concerns the interpretation of Article 138, Article 143(1)(d) and Article 143(2) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ 2006 L 347, p. 1), as amended by Council Directive 2009/69/EC of 25 June 2009 (OJ 2009 L 175, p. 12), (‘the VAT Directive’), and of the principles of tax neutrality and the protection of legitimate expectations.
The request has been made in proceedings between UAB ‘Enteco Baltic’ and the Muitinės departamentas prie Lietuvos Respublikos finansų ministerijos (Customs Department at the Ministry of Finance, Lithuania) (‘the Customs Department’) concerning the exemption from value added tax (VAT) of imports of fuel from Belarus into Lithuania followed by dispatch or transport of the fuel to other Member States.
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From the overview of Signatories of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) as available on the website of the OECD we understand that as per June 12, 2018 the total number of signatories to the CbC MCAA went up to 70.
From the overview we furthermore understand that Kazakhstan signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on June 12, 2018 and by doing so it became the latest signatory to the CbC MCAA.
Read more: Kazakhstan has signed the MCAA on the Exchange of Country-by-Country Reports
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