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On September 22, 2023 the mutual agreement on the implementation of the arbitration process pursuant to Article 25, Paragraph 5 of the Dutch-Swiss DTA as agreed between the Dutch and the Swiss competent authorities was published in the Dutch State Gazette. The agreement was signaed on September 22, 2022.
Some of the important matters arranged for in the mutual agreement include a.o.:
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On September 14, 2023 the Irish Department of Finance published a Roadmap for the Introduction of a Participation Exemption into the Irish Corporation Tax and opened a public technical consultation. The consultation period will run from September 14, 2023 to December 13, 2023. The technical consultation regards the introduction of a Participation Exemption and a potential introduction of an exemption for foreign branch profits in the Irish Corporation Tax.
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On September 20, 2023 on the website of the General Court of the EU a whole bunch of judgments of the Court was published that all regard the question whether or not the Belgian excess profit scheme constitutes illegal State Aid. At the bottom of this document you will find links to the texts of these judgements. In this article we will focus on the judgment in Case T‑131/16 RENV, Belgium versus the Commission, ECLI:EU:T:2023:561. In its judgment the Court for the second time confirms the decision of the European Commission which, in 2016, found that the Belgian ‘excess’ profits scheme infringed the EU rules on State aid.
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On September 20, 2023 the OECD published the comments it received on its public consultation of July 17, 2023 regarding Amount B of Pillar One regarding the simplification of transfer pricing rules.
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On September 12, 2023 the European Commission released a proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT). This Directive lays down a common set of rules for computing the tax base of large groups of companies in the European Union and replaces the Commission's CCTB (common corporate tax base) and CCCTB (common consolidated corporate tax base) proposals, which are withdrawn. If the proposal for the Directive is adopted Member States should apply the new rules as laid down in this Directive as of July 1, 2028.
Furthermore the European Commission released a proposal for a Council Directive on transfer pricing, which integrates key transfer pricing principles into EU law with the aim of putting forward certain common approaches for Member States. If the Directive is adopted, Member Sates should apply the new transfer pricing rules as of January 1, 2026.
In this article you will find a few of our initial remarks with respect to these 2 Directives.
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On September 4, 2023 the Dutch Secretary of State for Finances has sent a sent a summarization of the July 10-12 meeting of the Inclusive Framework (the IF) to the Dutch House of Commons. The letter gives some interesting insights in what has been discussed and on some of the views of the outgoing Dutch Government. In this article we focus on some of the interesting remarks made by the Secretary of State in his letter to the House of Representatives. The article is therefore not a full translation of the 5 page letter of the Dutch Secretary for Finances.
