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The Global Anti-Base Erosion (GloBE) Rules provide for a co-ordinated system of taxation intended to ensure large multinational enterprise (MNE) groups pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. It does so by imposing a top-up tax on profits arising in a jurisdiction whenever the effective tax rate, determined on a jurisdictional basis, is below the minimum rate.
Read more: How do the Pillar Two GloBE rules work? A high-level summary
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On December 17, 2021 we already informed you that the evening of the day before Pascal Saint-Amans finally broke silence and announced that The Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two would be released on Monday December 20, 2021.
Read more: The OECD Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two are available
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En date du 6 décembre 2021 et du 13 décembre 2021 les autorités compétentes du Luxembourg et de la France ont procédé à la signature d’un accord amiable sur la base de l'article 24, § 3 de la Convention entre le Gouvernement du Grand-Duché de Luxembourg et le Gouvernement de la République française en vue d’éviter les doubles impositions et de prévenir l’évasion et la fraude fiscales en matière d’impôts sur le revenu et sur la fortune, signée à Paris, le 20 mars 2018.
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On December 16, 2021 an interesting judgment of the Court of Appeal of The Hague was published on the website of the Dutch courts. The matter that was disputed is how the bonuses of a statutory director of a Dutch BV were to be taxed/whether or not based on DTAs the right to tax this income lay with third countries. Although this question in itself is a very interesting one, the matter that really attracted my attention were the arguments the taxpayer used in Court to defend its position and the indirect consequence they could have had for the Group. In this article I will therefore not focus on the outcome of the procedure but on the arguments tabled by the taxpayer and whether they might have adverse tax consequences for the Group.
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Some of us have been wondering why the GloBE rules of the OECD’s Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy were not published yet? And when they would be published.
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Yesterday we already reported that 2 Advocate General Priit Pikamäe had delivered two opinions in the Fiat State Aid Case. However our article was purely based on a press release issued by the Court of Justice of the European Union in this respect. However, as a tax lawyer I like to study actual text of the opinions. Unfortunately, until late yesterday evening I could not find them on the website of the CJEU.
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Update as per December 17, 2021
The full text of the Opinion as delivered by the Advocate General in Case C-898/19 P (Ireland versus the Commission_ you can find here.
The full text of the Opinion as delivered by the Advocate General in Case C-885/19 P (Fiat Chrysler Finance Europe v Commission) you can find here.
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Op 15 december 2021 heeft het Ministerie van Financiën een openbare consultatie geopend met betrekking tot 6 alternatieve maatregelen om dividendstripping effectiever aan te pakken. Geïnteresseerden kunnen tot en met 26 januari 2022 reageren op de consultatie.
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On December 15, 2021 the Dutch Government opened a public consultation regarding possibilities to strengthen measures to avoid dividend stripping. The Dutch Ministry of Finance is consulting the public regarding 6 alternative measures to more effectively tackle dividendstripping. The consultation will run until Januari 26, 2022.
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On December 14, 2021 the OECD/G20 the Luxembourg tax authorities issued a news letter announcing that the Belgian and Luxembourg competent authorities have agreed to extend the amicable agreement signed on May 19, 2020 by the competent authorities of Luxembourg and Belgium under article 25 § 3 of the Convention concluded between Luxembourg and Belgium and specifying the treatment of frontier workers for tax purposes in the context of the COVID-19 crisis. According to the news letter issued, the application of the agreement will be extended by tacit agreement until June 30, 2022, unless terminated at least two weeks before March 31, 2022.
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