DAC7 - reporting obligation digital platform operators
The digitalization of the economy and the rise of digital platforms has affected many business sectors. These developments have also led to a shift from traditional employment relationships based on employment contracts to the provision of services on a self-employed basis. There is thus a risk that the income sellers realize via digital platforms is not fully reported.
OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)
On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterprises with a revenue in excess of EUR 750 million.
European Commission’s response to the OECD Pillar 2 model rules
On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but have a broader scope that includes large-scale purely domestic groups.
New preliminary ruling question about the ‘fixed establishment’ concept for VAT purposes
On December 20, 2019 the Austrian Bundesfinanzgericht asked the Court of Justice of the European Union for a preliminary ruling on the concept of a ‘fixed establishment’ in the Titanium Ltd case (C-931/19). The case is not only relevant for property letting companies, but potentially also for all VAT taxable persons with foreign activities, as it may provide a more detailed interpretation of the EU concept of fixed establishment.