EU law

Pillar 2 Developments

On December 20, 2022 the OECD released three components of the Pillar 2 Implementation Framework. Our KPMG Pillar 2 specialists have prepared a summary of the content of these documents.

New referral to the CJEU – Net taxation – Taxation of dividend income received by a non-resident insurance company

On December 14, 2022 the Court of Appeals in ‘s-Hertogenbosch asked the Court of Justice of the EU (CJEU) for a preliminary ruling in a case dealing with net taxation.

EU reaches agreement on Pillar 2

This is a significant development as the EU is considered a first mover. Other countries are now likely to follow.

VAT in the Digital Age proposal issued to modernize the EU VAT system

The proposal from the European Commission covers three issues: (1) Digital Reporting Requirements (2) the VAT treatment of the platform economy and (3) changes to e-commerce rules and a ‘single VAT re ...

Court of Justice of the European Union rules that the UBO register must not be publicly accessible

The Minister of Finance has asked the Dutch Chamber of Commerce to temporarily stop providing information from the UBO register, effective as of November 22, 2022.

Dutch Supreme Court persists with strict interpretation of actual use for VAT recovery right purposes

This case is not only relevant for financial institutions, but also for other taxpayers performing VAT-taxed and VAT-exempt services.

Policy statement on Hybrid Mismatches updated; no longer double taxation in cost-plus situations

The spirit and intent of the anti-abuse measures is thus respected.

European Commission publishes proposal for a directive to tackle the misuse of shell entities

On December 22, 2021 the European Commission published a proposal for a directive aimed at preventing the misuse of shell entities and arrangements for tax purposes.

Report of the Conduit Companies Committee

The report contains 15 recommendations, divided into six tax and nine non-tax policy options. At the same time, the Deputy Minister of Finance sent the government’s response to this report to the Lowe ...

Pillar 2 Developments

New referral to the CJEU – Net taxation – Taxation of dividend income received by a non-resident insurance company

EU reaches agreement on Pillar 2

VAT in the Digital Age proposal issued to modernize the EU VAT system

Court of Justice of the European Union rules that the UBO register must not be publicly accessible

Dutch Supreme Court persists with strict interpretation of actual use for VAT recovery right purposes

Policy statement on Hybrid Mismatches updated; no longer double taxation in cost-plus situations

European Commission publishes proposal for a directive to tackle the misuse of shell entities

Report of the Conduit Companies Committee

Newsoverview

International

Contact & Offices