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.
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.
FS Tax Newsletter | June 2020
In this edition of the FS Tax Newsletter we address two developments initiated by the Dutch tax authorities: the further development of horizontal monitoring and the cancellation of rulings confirming the VAT exemption for investment management services provided to CLOs. We also discuss four other VAT-related subjects: an interesting judgment from the Court of Appeals Den Bosch regarding the VAT recovery methodology of a financial institution, the opinion of the Advocate General of the Court of Justice of the European Union on the VAT treatment of purchased investment management services that are used for both Special Investment Funds as well as non-Special Investment Funds, a judgment by the Noord-Holland District Court on the VAT position of a company pension fund, and recent developments with respect to the term ‘fixed establishment’ for VAT purposes