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On April 25, 2019 the OECD issued a press release announcing that on that same date Dominica signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. By doing so, Dominica became the 128th signatory to the convention.
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On April 10, 2019 on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Hogan in the Case C-291/18, Grup Servicii Petroliere SA versus Agenţia Naţională de Administrare Fiscală — Direcţia Generală de Soluţionare a Contestaţiilor Agenţia Naţională de Administrare Fiscală — Direcţia Generală de Administrare a Marilor Contribuabili (ECLI:EU:C:2019:302) was published.
Is an offshore ‘jackup’ drilling rig ‘a vessel used for navigation on the high seas …’? This is the principal question which this Court is now required to answer following a reference from the Curtea de Apel Bucureşti (Court of Appeal, Bucharest, Romania).
The present request has been made in proceedings between Grup Servicii Petroliere SA (‘GSP’), a company with its head office in Romania, and the Romanian tax authorities in a case concerning the VAT-exempt supply of three offshore jackup drilling rigs to particular Maltese companies. In that context, the referring court wishes to know whether offshore jackup drilling rigs of this kind are covered by the exemption laid down in Article 148(c) read in conjunction with Article 148(a) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ 2006 L 347, p. 1, ‘the VAT Directive’).
The effect of these provisions is that Member States are required in particular to exempt the supply of vessels used for navigation on the high seas and carrying passengers for reward or used for the purpose of commercial, industrial or fishing activities. As I have just noted, the essential question for consideration is whether these particular drilling rigs come within this exemption. Before considering this question it is first necessary to set out the relevant provisions of public international law, European Union law and national law.
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On April 9, 2019 the OECD announced that on the same date Luxembourg deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
Read more: Luxembourg deposits its instrument of ratification for the MLI
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Based on the overview of Jurisdictions Participating in the Convention on Mutual Administrative Assistance in Tax Matters as available on the website of the OECD, on March 28, 2019 Brunei Darussalam deposited its instrument of ratification, acceptance or approval for the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Brunei Darussalam signed the Convention on September 12, 2017.
