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(July 16, 2015)
On July 16, 2015 the European Court of Justice (CJEU) ruled in Joined Cases C‑108/14 and C‑109/14 Beteiligungsgesellschaft Larentia + Minerva mbH & Co. KG versus Finanzamt Nordenham (C‑108/14), and Finanzamt Hamburg-Mitte versus Marenave Schiffahrts AG (C‑109/14), (ECLI:EU:C:2015:496).
· Which calculation method is to be used to calculate a holding company’s (pro rata) input tax deduction in respect of input supplies connected with the procurement of capital for the purchase of shares in subsidiaries, if that holding company subsequently (as intended from the outset) provides various taxable services to those subsidiaries?
· Does the provision on the consolidation of several persons into a single taxable person in the second subparagraph of Article 4(4) of the Sixth Directive … preclude national legislation under which (first) only a legal person, but not a partnership, can be integrated into the undertaking of another taxable person (a so-called “Organträger” (controlling company)) and which (secondly) requires that this legal person “is integrated into the undertaking of the Organträger” in financial, economic and organisational terms (in the sense of a relationship of control and subordination)?
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(July 16, 2015)
On July 16, 2015 the UK HMRC opened consultations on a package of civil and criminal options to tackle offshore tax evaders and the enablers of offshore tax evasion. The government announced four consultations as part of its publication Tackling Evasion and Avoidance. These take forward HMRC’s strategy for tackling offshore evasion, No Safe Havens.
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(July 16, 2015)
The U.S. Department of the Treasury on its webpage that is dedicated to FATCA has published the FATCA Agreement that was concluded between the Government of the United States and the Government of the Republic of the Philippines.
Read more: FATCA IGA between the U.S. and the Philippines has been signed
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In today’s edition a.o.: OECD – High-Level Global Forum Tax Event on "Linking Transparency and Exchange of Information to Domestic Resource Mobilization"; European Commission – State aid: Commission opens two in-depth investigations into Hungary's food chain inspection fee and tax on tobacco sales; CJEU – Conclusion of Advocate General Kokott delivered in Case C-264/14 Hedqvist (VAT – Directive 2006/112/EC – Exchange of a virtual currency ‘Bitcoin’ for a traditional currency); CJEU – Conclusion of Advocate General Szpunar delivered in Case C-319/14 B&S Global Transit Center (Customs – Articles 203 and 204 Council Regulation EEC No 2913/92)
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(July 16, 2015)
On July 16, 2015 the Ministry of Finance of Japan issued a press release announcing that the Governments of Japan and Germany have agreed in principle on a new Agreement to be concluded. This new Agreement will replace the existing Agreement between Japan and the Federal Republic of Germany for the Avoidance of Double Taxation with respect to Taxes on Income and to certain other Taxes stemming from 1966.
Read more: Japan and Germany reach an agreement in principle on a new tax agreement to be concluded
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