Refund of Dutch dividend withholding tax based on Sofina judgment
This Decree potentially provides a meaningful option to foreign entities that have not been able to otherwise obtain relief for Dutch dividend withholding tax through either a reduced treaty tax rate or an exemption.
Year end 2020 tax accounting considerations
As the end of the year is fast approaching, many organizations will soon start preparing their year‑end financial statements. The announced 2021 Tax Plan may have a significant impact on those financials and especially the income tax position. The impact should be reflected once the 2021 Tax Plan is (substantively) enacted.
Legislative proposals on tightening CIT loss set-off and on Job-related Investment Allowance presented to Lower House
On October 5, 2020 the government presented two Memorandums of Amendment to the bill on the 2021 Tax Plan to the Lower House of Parliament. These memorandums had been announced on Budget Day.
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.