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On August 8, 2023 the Government of Bermuda issued a press release in which it announced that as a reaction to the Two Pillar solution of the OECD it is considering to introduce a corporate income tax to apply to Bermuda businesses that are part of Multinational Enterprise Groups (MNEs) with annual revenue of €750M or more. Also on August 8, 2023 the Bermuda Government opened what it calls a first public consultation regarding its considerations to implement such corporate income tax. The consultation period will end on September 8, 2023.
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On August 8, 2023 The Swiss Federal Department of Finance FDF has published a first report on the expected effects of the implementation of the OECD minimum tax on the individual cantons and on the measures planned by the cantons. The report is based on a survey of the cantons as of 31 May 2023.
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On August 4, 2023 the Canadian Government has opened consultations on several Budget 2023 measures to grow the clean economy, close tax loopholes, and deliver tax relief for Canadians. Two of the measures on which the Canadian Government opened a consultation are draft legislation to implement a Global Minimum Tax (Pillar Two) and draft legislation introducing a Digital Services Tax.
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De afgelopen tijd klinkt zowel binnen als buiten Nederland de roep om het vermogensgat tussen de (super-)rijken en de armen kleiner te maken steeds luider. Daarbij wordt er steevast voor gepleit om de (super-)rijken veel zwaarder te gaan belasten. De vraag die opkomt is hoe deze superrijken belast zouden moeten worden?
Read more: Belasten van (super-)rijken – VanMoof laat zien dat het snel kan verkeren
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The Dutch Ministry of Finance published an unofficial English translation of a Decree regarding the profit attribution to permanent establishments (in short the Decree profit attribution to permanent establishments 2022). The Dutch version of the Decree was already published on July 1, 2022 in the Dutch State Gazette.
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The Dutch Ministry of Finance published an unofficial English translation of a Decree regarding transfer prices, the application of the arm's length principle and the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines) (in short the Transfer Pricing Decree 2022). The Dutch version of the Decree was already published on July 1, 2022 in the Dutch State Gazette.
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On July 31, 2023 on the website of the Dutch Courts an interesting judgment of the Court of Appeal of 's-Hertogenbosch on the (double) residency of a BV (a limited liability company) that was incorporated under Dutch law was published (Case numbers: BKDH-21/01014 up to and including BKDH-21/01020, ECLI:NL:GHSHE:2023:2393). The case is interesting because in its judgment the Court gives a refreshment course on the steps to be taken in order to determine the place of residence of a legal entity.
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