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On march 23, 2016 the Swiss Federal Council issued a press release announcing that on that same date it adopted the dispatch on the tax information exchange agreement (TIEA) with Brazil and submitted it to parliament for approval.The Swiss-Brazilian TIEA was signed on November 23, 2015 and governs the exchange of information upon request in tax matters.

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In today’s edition: OECD – OECD releases standardised electronic format for the exchange of BEPS Country-by-Country Reports; Australia – Corporate tax transparency report for 2013-14 – Australian-owned resident private companies; Australia – Statement by Commissioner of Taxation, Chris Jordan AO on corporate tax transparency; The Netherlands – Beantwoording Kamervragen over trucs voor vermogenden; Canada – Budget 2016; Canada – Tax Measures: Supplementary Information (Budget 2016)

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In today’s edition: European Parliament – Six major European banks to explain their “tax optimisation” role to MEPs; Germany - Ent­wurf ei­nes BMF-Schrei­ben zur Be­triebs­stät­ten­ge­winnauf­tei­lung (Ver­wal­tungs­grund­sät­ze Be­triebs­stät­ten­ge­winnauf­tei­lung – VWG Bs­Ga); Tax Notes – Budget 2016; Jersey – Proposed amendment to UK Double Tax Arrangement; Guernsey – Guernsey agrees to amend DTA with UK; The Netherlands – Antwoorden op vragen over ontduiken btw-regels door internetbedrijven; Poland – Kierunki zmiany VAT

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On March 16, 2016 the Singaporean Ministry of Finance issued a press release announcing that on March 16, 2016 the Second Protocol Amending the Agreement Between the Government of the Republic of Singapore and the Government of the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (Hereafter: the Protocol) entered into force on March 16, 2016.

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Based on the table containing information with respect to DTAs concluded by Poland as available on the website of the Polish Ministry of Finance, the Convention between the Republic of Poland and Bosnia Herzegovina for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital as concluded on June 4, 2014 (Hereafter: the new DTA) entered into force on March 7, 2016. The new DTA will replace the Agreement between the Polish Peoples' Republic and Socialist Federal Republic of Yugoslavia for the avoidance of double taxation with respect to taxes on income and capital that was signed in Warsaw on January 10, 1985.

Based on Article 28, Paragraph 2 of the new DTA (“Entry into force”) the fact that the new DTA entered into force on March 7, 2016 means that its provisions shall have effect:

1)     in respect of taxes withheld at source, on income derived or capital owned on or after January 1, 2017, and

2)     in respect of other taxes, on income derived or capital owned in any tax year beginning on or after January 1, 2017.

 

With respect to the provisions of Articles 24 (“Mutual agreement procedure”) and 25 (“Exchange of information”) Article 28, Paragraph 3 subsequently arranges that they shall have effect from March 7, 2016, without regard to the taxable period to which the matter relates.

 

Below we will discuss some of the provisions of the DTA of which we think they might interest our readers.

  1. CJEU judges in Case C-40/15 Aspiro (VAT – Definition of ‘insurance’ transactions and of ‘related services performed by insurance brokers and insurance agents’)
  2. The opinion of the Advocate General in Case C-123/15, Feilen, has been published (Free movement of capital — Inheritance tax)
  3. The opinion of the Advocate General in Case C-11/15, Český rozhlas, has been published (VAT — Exemption from tax — Activities of non-commercial public radio and television bodies)
  4. The opinion of the Advocate General in Case C-18/15, Brisal, has been published (Freedom to provide services — National corporation tax — Income from interest)
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