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On March 29, 2022 the OECD released the standardised IT-format to support the electronic reporting and automatic exchange of information collected under the OECD's Model Reporting Rules for Digital Platforms (a XML Schema) as well as with a User Guide for Tax Administrations. These Model Rules require digital platforms to report on the income realised by those offering accommodation, transport and personal services, as well as those selling goods, through platforms and to report the information to tax authorities. In Europe this reporting obligation is implemented through the so-called DAC-7 Directive (Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation).
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As we reported in our article from March 9, 2022 during the Economic and Financial Affairs (ECOFIN) Council of March 15, 2022 the Council tried to come to an agreement on a general approach with respect to a compromise text for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. Last week it became already clear that parties did not come to an agreement on a compromise text.
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On March 24, 2022, the Japanese Ministry of Finance issued a press release that on that same date the mutual notifications necessary for the entry into force of the “Convention between Japan and the Kingdom of Morocco for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (signed on January 8, 2020) (Herafter: the Convention) were completed between the Government of Japan and the Government of the Kingdom of Morocco.
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On March 23, 2022 the Dutch cabinet sent a law proposal to implement the so-called DAC-7 Directive (Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation) into Dutch law to the House of Representatives. The expected date for entering into force of the law proposal is January 1, 2023. Consequently digital platforms will have to start registering the necessary data as of January 1, 2023.
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On March 22, 2022 the OECD launched a public consultation on a new tax transparency framework for crypto-assets and amendments to the Common Reporting Standard. In this respect the OECD released a public consultation document concerning a new global tax transparency framework to provide for the reporting and exchange of information with respect to crypto-assets, as well as proposed amendments to the Common Reporting Standard (CRS) for the automatic exchange of financial account information between countries. The purpose of the consultation is to inform policy makers decisions on the possible adoption of any such framework and its related design components.
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On March 17, 2022, on the website of the Court of Justice of the European Union (CJEU) the Judgment of the CJEU in Case C-545/19 AllianzGI-Fonds AEVN versus Autoridade Tributária e Aduaneira (ECLI:EU:C:2022:193), was published.
Introduction
Does the free movement of capital require a Member State to tax non-resident and resident investment vehicles according to the same tax system? That is the question which the Court must answer in this case. The question arises because Portugal, in exercise of its fiscal autonomy, has chosen to adhere, in the case of non-resident investment vehicles, to the conventional taxation of capital income by means of corporation tax withheld at source in cases where the corporations concerned are not subject to corporation tax or are subject to a low rate of corporation tax in their State of residence.
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During its meeting of March 15, 2022, the Economic and Financial Affairs (ECOFIN) Council adopted conclusions on the implementation of the VAT e-commerce package.
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On March 14, 2022, the Singaporean Ministry of Finance issued a press release announcing that the Convention between the Republic of Singapore and the Hellenic Republic for the elimination of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital signed on 30 May 2019 (Hereafter: the Convention), entered into force on 14 March 2022.
The OECD invites public input on the Implementation Framework of the global minimum tax (Pillar Two)
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On March 14, 2022, the OECD launched a public consultation on the Implementation Framework. Also on March 14, 2022 the Inclusive Framework released the Commentary on the GloBE Rules, which provides MNEs and governments with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules.
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On March 14, 2022, the Inclusive Framework on BEPS released Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) (224 pages). Furthermore the OECD also released illustrative examples regarding the application of the Model GloBE Rules to certain fact patterns (44 pages).
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