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In today’s edition a.o.: Poland – Nowe regulacje dotyczące stosowania zwolnienia dla dywidend
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(July 21, 2015)
On July 10, 2015 the Dutch Supreme Court ruled with respect to tax loss carry-back in a case where there were subsequent fiscal unities formed for Dutch corporate income tax purposes (ECLI:NL:HR:2015:1779). Under current regulations Net Operating Losses (NOLs) can be carried back to the previous year and carried forward to the following nine financial years. During the years 2009 and 2010 taxpayers were given the opportunity to opt for a system in which NOLs could be carried back to the previous three financial years and carried forward to the six following financial years. The underlying case regards the regulations as applied in 2009 and 2010. Although it therefore seems only interesting for a limited number of similar cases, in our view the case is still interesting because it gives an example of some of the (un-)wanted effects that joining a fiscal unity during a financial year might have.
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(July 21, 2015)
On July 20, 2015 the UK HM Revenue and Customs published a guidance titled: “Investment managers: Capital Gains Tax treatment of carried interest (July 2015)”. The document supposedly gives guidance on the Capital Gains Tax treatment of carried interest legislation announced at Summer Budget 2015 which will have effect from July 8, 2015.
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(July 20, 2015)
The European Parliament’s Special Committee on Tax Rulings and Other Measures Similar in Nature or Effect (TAXE) has announced that its co-rapporteurs (Elisa Ferreira & Michael Theurer) will present their draft report in the evening of September 7, 2015 during the next meeting of TAXE.
Read more: SAVE THE DATE: TAXE to present its draft report on September 7, 2015
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(July 19, 2015)
On July 17, 2015 the Irish Revenue published Revenue eBrief No. 73/15 “VAT & Pension Funds - Revenue's position following judgments of the CJEU”. Via the eBrief the Irish Revenue informs the public that the VAT Manual has been updated to set out the VAT treatment applying to pension funds following decisions of the Court of Justice of the European Union (CJEU) in Wheels (Case C-424/11), ATP (Case C-464/12) and PPG (Case C-26/12).
The eBrief is divided into 2 parts. The first part regards the VAT treatment of management services supplied to pension funds, whereas the second part regards the VAT deductibility in respect of pension fund costs.
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