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International Tax Plaza’s Newsletter from November 1, 2015

 

 

In this edition:

·        Calendar for November 2 – November 8, 2015

·        CJEU judges in Case C-174/14 Saudaçor (VAT – Article 13(1) of Directive 2006/112/EC – Concept of ‘body governed by public law’)

·        Quick News from October 29, 2015

·        Inland Revenue Authority of Singapore publishes the second edition of its e-Tax Guide – GST: Guide for Property Owners and Property Holding Companies

·        Swiss - Argentine DTA to enter into force on November 27, 2015

·        U.S. Government publishes a Technical Explanation of the Protocol amending the U.S. – Japanese DTA

·        The OECD has published the full version of its Model Tax Convention on Income and on Capital (2014 version)

·        Quick News from October 30, 2015

·        13 new jurisdictions have signed the Multilateral Competent Authority Agreement

·        OECD - The Global Forum on Transparency and Exchange of Information for Tax Purposes publishes 15 new peer review reports

·        Great career opportunities

 

Calendar for November 2 – November 8, 2015

 

A.o. the Inaugural Meeting of the Multilateral Instrument Ad Hoc Group, a CREDAF Working Group Meeting on BEPS, the 20th Global Forum on Tax Treaties and the 3rd meeting of the Global Forum on VAT…   View the calendar on International Tax Plaza

 

 

 

CJEU judges in Case C-174/14 Saudaçor (VAT – Article 13(1) of Directive 2006/112/EC – Concept of ‘body governed by public law’)

 

Published: 29 October 2015 

On October 29, 2015 the Court of Justice of the European Union (CJEU) judged in Case C‑174/14 Saudaçor — Sociedade Gestora de Recursos e Equipamentos da Saúde dos Açores SA versus Fazenda Pública (ECLI:EU:C:2015:733).

·         Must the concept of body governed by public law within the meaning of the first paragraph of Article 13(1) of Directive 2006/112 be interpreted ... by reference to the concept of “body governed by public law” [as defined in] Article 1(9) of Directive 2004/18?

 

·         Is an entity established as a limited company, with exclusively public capital and 100% owned by the RAA, and whose object is the exercise of consultancy and management activities in matters relating to the regional health service, with the purpose of developing and reorganising it through the performance of programme agreements concluded with that region, which holds by delegation the public-authority powers conferred in those matters on the region which was originally responsible for providing the public health service, covered by the concept of a “body governed by public law” acting as a public authority for the purpose of the first subparagraph of Article 13(1) of Directive 2006/112?

 

·         In the light of the provisions of that directive, may the consideration received by that company, which consists in the making available of the financial resources necessary for the performance of those programme agreements, be regarded as payment for the services provided, for the purposes of liability to VAT?

 

·         If so, does that company satisfy the requirements necessary in order to be entitled to rely upon the rule governing not being regarded as a taxable person laid down in Article 13(1) of Directive 2006/112?...   Read the article on International Tax Plaza

 

 

 

Quick News from October 29, 2015

 

In today’s edition: CJEU – Judgement delivered in Case C-589/14, Commission v Belgium (Free movement of capital - Belgium - interest withholding tax); European Commission - VAT: the report on national rules applied for the use of the mini one-stop shop and the overview have been updated; European Commission - VAT: Explanatory Notes on the place of supply rules for services connected with immovable property are available on our website...   Read the article on International Tax Plaza

 

 

 

Inland Revenue Authority of Singapore publishes the second edition of its e-Tax Guide – GST: Guide for Property Owners and Property Holding Companies

 

Published: 29 October 2015

 

On October 29, 2015 the Inland Revenue Authority of Singapore published its IRAS e-Tax Guide – GST: Guide for Property Owners and Property Holding Companies (Second Edition). According to the e-Tax Guide the aim of the guide is to explain how GST affects you as a property owner or a property holding company. Supposedly the e-Tax Guide guides you on the application of GST for property transactions and it is supposed to help you decide whether you need to register for GST if you are involved in property transactions. It is furthermore stated that the guide also clarifies the type of property that qualifies for GST exemption…   Read the article on International Tax Plaza

 

 

 

Swiss - Argentine DTA to enter into force on November 27, 2015

 

Published: 29 October 2015

 

On October 29, 2015 the Swiss Federal Department of Finance issued a press release announcing that the Convention between the Swiss Confederation and the Argentine Republic for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital (Hereafter: the Convention) will enter into force on November 27, 2015…   Read the article on International Tax Plaza

 

 

 

U.S. Government publishes a Technical Explanation of the Protocol amending the U.S. – Japanese DTA

 

Published: 30 October 2015

 

On January 14, 2013 the U.S. and Japan signed a Protocol amending the Convention between the Government of the United States of America and the Government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and the Protocol, which forms and integral part of the Convention, signed at Washington on November 6, 2003. On October 29, 2015 on the website of the U.S. Department of the Treasury a so-called Technical Explanation of this Protocol was published…   Read the article on International Tax Plaza

 

 

 

The OECD has published the full version of its Model Tax Convention on Income and on Capital (2014 version)

 

Published: 30 October 2015

 

On October 30, 2015 the OECD made the full version its Model Tax Convention on Income and on Capital (as it reads on July 15, 2014) available via its website (or at least they intended to, because when we tried to read the online version, it seemed that the first 1,000 pages were unreadable and the same can be said regarding the last 289 pages)…   Read the article on International Tax Plaza

 

 

 

Quick News from October 30, 2015

 

In today’s edition a.o.: The UK – Accounting standards: the UK tax implications of new UK GAAP; The UK – Revenue and Customs Brief 18 (2015): VAT grouping rules and the Skandia judgement; The UK – Corporation Tax treatment of interest-free loans and other non-market loans; The UK – Corporation Tax: Disregard Regulations for derivative contracts; Hong Kong – Application form for Certificate of Hong Kong Resident Status under the Comprehensive Arrangement for the Avoidance of Double Taxation between the Mainland and Hong Kong will be revised with effect from 1 November 2015; The Netherlands – 2e nota van wijziging Belastingplan 2016; The Netherlands – Tweede Nota van Wijziging MDR; The Netherlands – ECLI:NL:PHR:2015:2197, Conclusie van de AG (deelneming - reorganisatie - valutaverliezen)…   Read the article on International Tax Plaza

 

 

 

13 new jurisdictions have signed the Multilateral Competent Authority Agreement

 

Published: 31 October 2015

 

On October 29 and 30, 2015 the 8th Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes took place. On October 30, 2015 the OECD issued a press release regarding this 8th meeting in which a.o. it was announced that during the meeting 13 new jurisdictions signed the Multilateral Competent Authority Agreement, bringing the total number of signatories to 74…   Read the article on International Tax Plaza

 

 

 

OECD - The Global Forum on Transparency and Exchange of Information for Tax Purposes publishes 15 new peer review reports

 

Published: 31 October 2015

 

On October 29 and 30, 2015 the 8th Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes took place. In connection with this meeting the Global Forum published 16 new peer review reports…   Read the article on International Tax Plaza

 

 

 

Great career opportunities

 

In the original newsletter here the latest job postings were listed.

 

 

 

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