- Details
On December 1, 2021, DIRECTIVE (EU) 2021/2101 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 24 November 2021 amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches was published in the Official Journal of the European Union. The Directive will This Directive shall enter into force on December 21, 2021. Based on Article 2, Paragraph 1 of the Directive Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by June 22, 2023. Based on Article 48g that is to be inserted in Directive 2013/34/EU ("Commencement date for reporting on income tax information") Member States shall ensure that laws, regulations and administrative provisions transposing Articles 48a to 48f apply, at the latest, from the commencement date of the first financial year starting on or after June 22, 2024.
- Details
On November 25, 2021, on the website of the Court of Justice of the European Union (CJEU) the judgment of the Court in Case C- 437/19 État luxembourgeois versus L (ECLI:EU:C:2021:953), was published.
- Details
On November 25, 2021, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a new peer review report on transparency and exchange of information on request (EOIR) for Kenya, and three first-time reviews for Côte d’Ivoire, Moldova and Tanzania.
- Details
On November 25, 2021, on the website of the Court of Justice of the European Union (CJEU) the judgment of the Court in Case C- 334/20 Amper Metal Kft. versus Nemzeti Adó- és Vámhivatal Fellebbviteli Igazgatósága ((Resources Directorate of the National Tax and Customs Authority, Hungary) (ECLI:EU:C:2021:961), was published.
- Details
On October 28, 2021 the Swedish Government submitted a bill proposing the introduction of a so-called tax risk. Under the proposal a tax liability will arise in the event of a “simplified indebtedness” within the taxpayer group (attributable to its operations in Sweden) which, as per the beginning of the financial year, is equal to or greater than SEK 150 billion (excluding intra-group indebtedness and provisions).
- Details
On November 22, 2021, a report of the Dutch Conduit Companies Committee (The Committee Ter Haar) was released. At the request of the House of Representatives the Committee has spent six months investigating the activities of conduit companies in the Netherlands, also sometimes referred to as letterbox companies.
In the report, the Committee discusses the phenomenon of conduit companies in a broad sense, including the nature, the scope and the cause of this phenomenon. Particular attention is paid to three main themes:
1. What is the extent of conduit activities and their contribution to the Dutch economy?
2. What are the tax motives for conduit activities in the Netherlands?
3. What are the non-tax motives for conduit activities in the Netherlands?
4. What is the relationship between money laundering and tax avoidance?
5. What is the effect of (recent) international developments?
- Details
On November 19, 2021, on the website of the Dutch courts (De Rechtspraak) a very interesting judgment of the Court of Appeal of The Hague in the Joined Cases with case numbers: BK-19/00754 upto and including BK-19/00758, ECLI:NL:GHDHA:2021:2143 was published. The judgment already dates from October 27, 2021, but it was only published on November 19, 2021.
In the underlying case the taxpayer and the tax authorities a.o. are disputing whether or not a currency exchange gain that the ‘taxpayer’ realized on so-called Forwards Swap Agreements is to be attributed to the foreign permanent establishment of the ‘taxpayer’. We say ‘taxpayer’ because the permanent establishment is actually the permanent establishment of a subsidiary that is included in the fiscal unity of which the taxpayer is the parent entity.
- Details
On November 15, 2021, Shell announced that it seeks approval shareholder approval to simplify its corporate structure and that it intends to move its tax residency to the UK. So what has happened since then?
Read more: Shell’s intention to move its tax residency to the UK – What has happened since then?
- Details
On November 18, 2021, on the website of the Court of Justice of the European Union (CJEU) the judgment of the Court in Case C- 358/20 Promexor Trade SRL versus Direcția Generală a Finanțelor Publice Cluj – Administrația Județeană a Finanțelor Publice Bihor (ECLI:EU:C:2021:936), was published.
Read more: CJEU judgment in Case C-358/20, Promexor Trade, published (VAT – Revocation of the VAT...
- Details
On November 17, 2021 the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes launched the Women leaders in tax transparency programme. The programme which aims at reinforcing gender equality in tax administrations.
Page 1 of 3
