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On November 9, 2021, The Irish Department of Finance published the responses it received on its Feedback Statement on ATAD Anti-Reverse Hybrid Rule. On July 2, 2012 The Irish Department of Finance published a Feedback Statement: “ATAD Implementation - Article 9a Reverse Hybrid Mismatches” and invited interested parties to respond to this Feedback Statement.
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On November 8, 2021, the Japanese Ministry of Finance issued a press release announcing that on November 5, the exchange of diplomatic notes between the Government of Japan and the Government of the Republic of Serbia for the entry into force of the “Convention between Japan and the Republic of Serbia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (signed on July 21, 2020) (hereafter: the Convention) took place in Belgrade.
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On November 5, 2021, the Swiss State Secretariat for International Financial Matters issued a press release announcing that already on July 27, 2021 the Convention between Switzerland and Bahrain for the elimination of double taxation with respect to taxes on and on capital and the prevention of tax evasion and tax avoidance entered into force. Consequently the provisions of the double taxation agreement (DTA) will apply from January 1, 2022.
Read more: The DTA between Switzerland and Bahrain has entered into force
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On November 5, 2021, the Japanese Ministry of Finance issued a press release announcing that on that same date, the Government of Japan and the Government of Kingdom of Denmark exchanged diplomatic notes concerning the entry into force of Article 24, Paragraph 5 of the “Convention between Japan and the Kingdom of Denmark for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” which entered into force in 2018 (Herafter: the Convention).
Read more: The arbitration provisions of the Danish-Japanese DTA entering into force
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On November 5, 2021, the Irish Department of Finance launched a public consultation seeking stakeholder views on the introduction of new taxation measures to apply to outbound payments. The public and interested stakeholders are invited to give their views on the issues detailed in the public consultation document. According to the consultation document it is anticipated that any changes decided upon will be considered in the context of the Finance Bill 2022 or 2023, also taking into account recent developments and ongoing discussions at the OECD Inclusive Framework. The consultation period will run from November 5, 2021 to December 20, 2021.
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On October 29, 2021, we already reported on the judgment of the Court of Justice of the EU (CJEU) in Case C-324/20, X-Beteiligungsgesellschaft (TVA – Paiements successifs). The case regards the interpretation of the Articles 64 Paragraph 1 and 90 Paragraph 1 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax. This judgment and the way how the CJEU interprets Articles 64 Paragraph 1 and 90 Paragraph 1 of Council Directive 2006/112/EC can cause serious cashflow issues in case of a one-time supply of services, which are remunerated by means of payment in installments.
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