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On December 24, 2021 the Dutch Supreme Court ruled on the interpretation of Article 15, Paragraph 3 of the Convention between the Kingdom of the Netherlands and the Swiss Confederation for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance.
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On December 22, 2021 the Maltese Commissioner for Revenue opened a public consultation on draft transfer pricing rules it intends to introduce as per January 1, 2024. The consultation period will end on February 28, 2022.
In 2021 an enabling provision (Article 51A) has been introduced into the Income Tax Act enabling the making of rules in relation to transfer pricing and Advance Pricing Agreements (APAs).
Read more: The Maltese Government opened a consultation on draft transfer pricing rules
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As we already reported on December 22, 2021 on that same date the European Commission released a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU.
Also on December 22, 2021 the European Commission released a proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (Implementation of Pillar-Two).
And lastly also on December 22, 2021 the European Commission proposed to establish the next generation of own resources for the EU budget by putting forward three new sources of revenue: the first based on revenues from emissions trading (ETS), the second drawing on the resources generated by the proposed EU carbon border adjustment mechanism, and the third based on the share of residual profits from multinationals that will be re-allocated to EU Member States under the recent OECD/G20 agreement on a re-allocation of taxing rights (“Pillar One”).
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On December 25, 2021 we published our article high-level analysis of the European Commission’s proposal for a Directive laying down rules to prevent the misuse of shell entities. For those that want to get a quick high-level understanding of the European Commission’s Proposal for a COUNCIL DIRECTIVE laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU, which was released on December 22, 2021 below you will find 15 slides to give you a quick understanding of the proposed Directive.
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On December 22, 2021, the Irish Department of Finance opened a public consultation regarding a potential move from its current credit method of double taxation relief (a worldwide system of taxation) to an exemption method (a territorial system of taxation). The consultation period will run until March 7, 2022.
A worldwide regime considers all profits, both domestic and foreign source, of a resident entity to be within scope of taxation. Whereas fully territorial regimes focus on the taxation of income and gains earned in the territory and exempt foreign-source profits of resident entities.
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On December 22, 2021, the European Commission released a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. In this article we make a high-level analysis of the regulations as laid down in this Directive and we inserted slides that we hope are useful for the understanding of our readers.
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On December 22, 2021, the European Commission proposed to establish the next generation of own resources for the EU budget by putting forward three new sources of revenue: the first based on revenues from emissions trading (ETS), the second drawing on the resources generated by the proposed EU carbon border adjustment mechanism, and the third based on the share of residual profits from multinationals that will be re-allocated to EU Member States under the recent OECD/G20 agreement on a re-allocation of taxing rights (“Pillar One”). At cruising speed, in the years 2026-2030, these new sources of revenue are expected to generate on average a total of up to €17 billion annually for the EU budget.
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On December 22, 2021 the European Commission released a proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. The proposal delivers on the EU’s pledge to move extremely swiftly and be among the first to implement the recent historic global tax reform agreement, which aims to bring fairness, transparency and stability to the international corporate tax framework.
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On December 22, 2021, the European Commission released a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. This so-called “Unshell proposal” should ensure that entities in the European Union that have no or minimal economic activity are unable to benefit from any tax advantages and do not place any financial burden on taxpayers. The purpose of the proposal is to protect the level playing field for the vast majority of European businesses and to ensure that ordinary taxpayers do not suffer additional financial burden due to those that try to avoid paying their fair share.
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A year is nearing its end. So a new year will start soon. And for the Netherlands that always means that it is time to have a look at what will be the most important changes for Dutch corporate income tax purposes that come into force as per January of the following year. So below you will find a high level description of some important changes that based on the Belastingplan 2022 (The Tax Act 2022) and some other measures that the Dutch Eerste Kamer (House of Lords) approved on December 21, 2021will come into force in the Netherlands as per January 1, 2022.
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