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On March 1, 2017 the South African Revenue Service SARS published Binding Private Ruling: BPR 26. The ruling determines whether dividends tax must be withheld when a dividend is paid to the beneficial owner that is a resident of the Kingdom of Sweden.
Sweden and South Africa concluded a DTA which, when read with the Protocol, includes a ‘most favoured nation’ clause.
Read more: Dividend withholding tax under the Swedish – South African DTA
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On March 3, 2017 the New Zealand Government published 3 BEPS consultation papers proposing new measures to strengthen New Zealand’s rules for taxing large multinationals. The consultation documents contain proposals for:
· Transfer pricing and permanent establishment avoidance;
· Preventing multinationals using interest payments to shift profits offshore; and
· New Zealand’s implementation of the multilateral convention to implement tax treaty related measures to prevent BEPS.
Closing date for the consultation of New Zealand’s implementation of the multilateral convention to implement tax treaty related measures to prevent BEPS is April 7, 2017. The closing date for the other 2 consultations is April 18, 2017.
Read more: New Zealand Government releases 3 BEPS documents for consultation
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On November 29, 2016 the Australian Government released exposure draft legislation for a Diverted Profits Tax (DPT) for consultation. The closing date for submissions was December 23, 2016. The Australian Treasury has now published the submissions it received for this consultation.
According to the Australian Treasury 21 submissions were received for this consultation. This included 2 confidential submissions. These 2 confidential submissions were not published by the Australian Treasury.
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Earlier we have already reported that the Chairman of the European Parliament’s Committee of inquiry to investigate alleged contraventions and maladministration in the application of Union law in relation to money laundering, tax avoidance and tax evasion (Hereafter: PANA) has requested the highest political level of responsibility of each respective EU Member State to provide PANA with information about the relevant national legal definition(s) of tax-related crimes, about the organization of tasks between the national administrations and the judiciary and about staff resources and working methods, as well as about the results achieved to date.
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On March 2, 2017 on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Szpunar in the Case C-553/15, European Commission versus Ireland (ECLI:EU:C:2017:162) was published.
Registration taxes on motor vehicles are not harmonised in EU law. Therefore, the Member States essentially have the right to shape that type of tax as they see fit. However, they cannot do so in a manner contrary to the general principles of EU law, including, in particular, the freedoms of the single market. This case concerns the extent of the Member States’ freedom in this field.
Ireland, which was requested by the European Commission to adjust its system of registration taxes to satisfy the requirements of the freedom to provide services in relation to motor vehicle rental and leasing services, made appropriate amendments to its national law. However, the Commission takes the view that, in relation to motor vehicles imported into Ireland from other Member States for use for a fixed period, the adjustments made in Irish law are insufficient and that that law remains contrary to the freedom to provide services. Since Ireland takes a different view, the dispute will have to be resolved by the Court.
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