INTERNATIONAL TAX PLAZA - News archive 2021

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INTERESTING ARTICLES

The Court of Appeal of The Hague ruled in 3 similar cases on the relevance of the outcome of a Mutual Agreement Procedure for earlier years
The opinion of the Advocate General in Case C‑321/24, Attal and Associés (Free movement of capital – Declaration of succession – Calculation of notary’s remuneration)
Position of the Dutch tax authorities on the application of the withholding exemption of the Dutch dividend withholding tax Act in cases the dividend is not eligible for treaty benefits
The Inclusive Framework on BEPS released a consolidated version of the Commentary to the Global Anti-Base Erosion Model Rules
Memorandum of Understanding as concluded by the Dutch and German Ministries of Finance on their intend to continue their discussion on the tax consequence of teleworking by cross-border workers
The DAC9 Directive has been published in the Official Journal of the European Union
Protocol amending the existing DTA as concluded between the Kingdom of the Netherlands and the Federal Republic of Germany has been published in the Dutch State Gazette
Competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent BEPS as concluded between the competent authorities of Belgium and The Netherlands
The Council of the European Union adopted the DAC9 Directive
The CJEU ruled in Case C-228/24, Nordcurrent group (The anti-abuse provision of the Parent-Subsidiary Directive)
The opinion of the Advocate General in the joined Cases C‑92/24 to C‑94/24, Banca Mediolanum, Banca Mediolanum – II and Banca Mediolanum – III (The interpretation of Article 4 of the Parent Subsidiary Directive)
The CJEU ruled in Case C-135/24, John Cockerill (The interpretation of Article 1, Paragraph 4 and Article 4 of the parent-subsidiary directive)
The European Commission calls on Spain to allow for a deduction of directly related expenses when calculating the withholding tax due over cross-border royalty payments
The European Commission decides to refer Spain to the CJEU due to discriminatory tax treatment of non-resident taxpayers