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On June 20, 2016 the Dutch Government opened a consultation on proposed amendments to the interest limitation rules as included in the Articles 15ad and 10a of the Dutch corporate income tax Act. According to an announcement made in this respect, it is the Dutch Government’s intention to include these changes in the package Belastingplan 2017 (Tax Plan 2017) and to have the new regulations to enter into force on January 1, 2017. The aim of the amendments is to have the existing anti-abuse legislation to apply in more different situations. The consultation will run from June 20, 2016 through July 18, 2016.
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On June 22, 2016 the U.S. Department of the Treasury issued a statement regarding bilateral tax treaty negotiations between the United States and Luxembourg and the treatment of certain permanent establishments. The statement regards current negotiations of a protocol to amend a number of provisions of the U.S. – Luxembourg tax treaty, signed at Luxembourg on April 3, 1996, and entered into force on December 20, 2000. And more particular regarding the efforts that the governments of the United States and Luxembourg are undertaking to avoid the double non-taxation of permanent establishments as under conditions might incur under the U.S. – Luxembourg tax treaty as its is currently in place.
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On June 17, 2016 the Swiss Parliament had a voting session. During this session the Swiss Parliament a.o. voted on several (Protocols to amend) DTAs and TIEAs as well as on the Amending Protocol to the Agreement Between the Swiss Confederation and the European Community Providing for Measures Equivalent to Those Laid Down in Council Directive 2003/48 EC on Taxation of Saving Income in the Form of Interest Payments.
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On June 22, 2016 the Court of Justice of the European Union (CJEU) judged in Case C-267/15 Gemeente Woerden versus Staatsecretaris van Financiën (ECLI:EU:C:2016:466).
This request for a preliminary ruling concerns the interpretation of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax.
In a case such as the present, in which a taxable person has had a building constructed and has sold that building for a price which does not cover all of the costs, while the purchaser of the building has given a certain part thereof to a third party for the latter’s use free of charge, is that taxable person entitled to deduct all of the VAT invoiced in respect of the construction of the building, or only a part thereof, in proportion to the parts of the building which the purchaser uses for economic activities (in the present case, the grant of a lease for consideration)?
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On June 22, 2016 the Court of Justice of the European Union (CJEU) judged in Case C-11/15 Odvolací finanční ředitelství versus Český rozhlas (ECLI:EU:C:2016:470).
This request for a preliminary ruling concerns the interpretation of Article 2(1) of Sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonisation of the laws of the Member States relating to turnover taxes — Common system of value added tax: uniform basis of assessment.
The request has been made in proceedings between the Odvolací finanční ředitelství (Appellate Tax Directorate; ‘the Tax Directorate’), formerly the Finanční ředitelství pro hlavní město Prahu (Prague City Tax Directorate, Czech Republic), and Český rozhlas (Czech Radio) concerning value added tax (VAT) for which it was liable in connection with its public broadcasting activity.
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