FS Tax Newsletter | January 2020

Last year our first FS Tax Newsletter for 2019 discussed the CJEU judgment rendered in the Morgan Stanley case, concerning the right of a branch to recover input VAT if it (partially) provides support services to the head office in another EU Member State. We will be discussing in this newsletter a similar matter that has been presented to the CJEU for a preliminary ruling in the Bank of China case. We also discuss another case concerning the VAT position of fixed establishments. It seems that branches and VAT are still a hot topic in 2020. 

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FS Tax Newsletter | November 2019

In this edition we highlight the key aspects of the 2020 Tax Plan. We also focus on three important CJEU cases concerning the VAT payable on assignment of a debt recognized in enforcement proceedings, VAT and services related to the operation of ATMs and VAT on services provided by a head office to its fixed establishment. Finally, we would like to invite you to a seminar on the OECD BEPS 2.0 / Pillar Two consultation and to a roundtable for pension funds and asset managers (see points 5 and 6).

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KPMG submission on ‘Pillar One’ approach to address digital economy tax issues

This week KPMG submitted its comments to the Organisation for Economic Co-operation and Development (OECD) consultation with regard to the unified approach under Pillar One.

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EU Anti-Tax Avoidance Directive 2: hybrid mismatches with third countries

On February 21, 2017 the EU Member States reached agreement on a Directive that will amend the Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164 of July 12, 2016, ’ATAD 1’). The new Directive (‘ATAD 2’) amends Article 9 of ATAD 1, which covered certain hybrid mismatches between EU Member States. 

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Country-by-Country Reporting – Additional rules for exchanging Country-by-Country reports and OECD update

On January 17, 2017 a bill to implement Council Directive (EU) 2016/881 (‘DAC4’) concerning Country-by-Country Reporting (‘CbCR’) was presented to the Lower House of the Dutch Parliament. Please refer to our previous memorandum on this. On March 21, 2017 the Memorandum of Amendment (Nota van Wijziging; ‘NvW’) and the Memorandum in response to the Report (Nota naar aanleiding van het Verslag; ‘NaV’) were sent to the Lower House. On April 18, 2017 the Lower House adopted the bill (34 651) and an amendment (no. 13) on the maximum penalty. 

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Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Netherlands and other countries

On June 7, 2017, the Dutch Minister of Finance Dijsselbloem and other high-level representatives of 67 countries representing 68 jurisdictions signed the Multilateral Convention (“Multilateral Instrument” or “MLI”) to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) and improve dispute resolution mechanisms. 

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Dutch Lower House of Parliament passes Bill on ratification of the MLI

On February 12, 2019 the Dutch Lower House of Parliament passed the Bill for the ratification of the Multilateral Convention (“MLI”) to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) and improve dispute resolution mechanisms. Noteworthy is that the Lower House also agreed to change the MLI position of the Netherlands with respect to preventing the artificial avoidance of permanent establishment status. 

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Tax advice relating to tax treaties

Do you need tax advice about the application of tax treaties to your company or work done abroad? Our specialists are here to help you. Read more about what we can do for you.

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