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On May 31, 2023 the Dutch Government sent a draft bill to implement a 15% minimum taxation for large multinational groups and large domestic enterprises to the Dutch parliament. In this article we will mention a few of our initial remarks.
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On May 30, 2023 the Swiss Federal Council and the Government of the Republic of Slovenia signed a protocol amending the Convention between the Swiss Federal Council and the Government of the Republic of Slovenia for Avoidance of Double Taxation with respect to Taxes on Income and on Capital, signed at Ljubljana on June 12, 1996, as amended by the Protocol signed at Ljubljana on September 7, 2012 (The Protocol).
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The U.S. Committee on Ways and Means launched an attack on Pillar 2, more specifically on the introduction of the UTPR by third countries. On May 25, 2023 the Ways and Means Committee Chairman Jason Smith, along with every Committee Republican, introduced H.R. 3665, the Defending American Jobs and Investment Act. In a press release issued by the Committee it is stated that the purpose of the bill is to prevent President Biden’s global tax surrender from killing American jobs, surrendering sovereignty over our tax code, and handing a competitive advantage to the Chinese Communist Party. The bill creates a reciprocal tax applicable to any foreign country that imposes unfair taxes on U.S. businesses and workers under the Organization for Economic Co-operation and Development (OECD)’s global tax deal.
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The OECD/G20 minimum taxation for large multinational enterprises is to be implemented in Switzerland with a supplementary tax. On June 18, 2023, the Swiss electorate will vote on the requisite constitutional basis. If this basis is accepted, the Swiss Federal Council can temporarily introduce the supplementary tax by means of an ordinance. At its meeting on May 24, 2023 the Federal Council opened the second consultation procedure on this ordinance. The consultation period runs until September 14, 2023.
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On May 23, 2023 the Socialist Republic of Viet Nam has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (The BEPS Convention). The BEPS Convention will enter into force on September 1, 2023 for Vietnam.
Read more: Vietnam deposited its instrument for the ratification of the Multilateral BEPS Convention
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On May 18, 2023 the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill, which amongst others will implement the OECD Global Anti-Base Erosion (GloBE) rules in New Zealand, was introduced into New Zealand’s Parliament. New Zealand intends to implement the Income Inclusion Rule (IIR), a Domestic Income Inclusion Rule (DIIR) and an Undertaxed Profits Rule (UTPR). In order to implement the GloBE rules the Bill contains the several amendments to the New Zealand Income Tax Act 2007.
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On May 11, 2023 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in the Joined Cases C-407/22 (Ministre de l’Économie, des Finances et de la Relance versus Manitou BF SA) and C-408/22 (Ministre de l’Économie, des Finances et de la Relance versus Bricolage Investissement France SA), ECLI:EU:C:2023:392, was published.
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In the Official Journal of the European Union of May 8, 2023 the action as lodged on March 15, 2023 by VF against the Council of the European Union, regarding Article 17 (International shipping income exclusion) of the EU Directive ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union, was published.
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In the Official Journal of the European Union of May 8 the request for a preliminary ruling as lodged on February 10, 2023 by the Court of First Instance of Liège (Belgium) in Case C-73/23, Chaudfontaine Loisirs (Chaudfontaine Loisirs SA versus État belge), was published.
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In this article we discuss position paper KG:024:2023:1 of February 16, 2023. In this position paper the Knowledge Group on dividend withholding tax and other withholding taxes answers the question whether the purchase of shares in its parent company by a subsidiary against admission of guilt in the form of shares in the subsidiary qualifies as an indirect purchase for the Dutch dividend withholding tax (DDWT) Act.
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