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On April 14, 2022 the Irish Ministry of finance opened a public consultation in relation to the Research & Development Tax Credit and the Knowledge Development Box. The consultation period runs from April 14 until May 30, 2022.
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As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD announced on April 14, 2022 that it is seeking public comments on the Extractives Exclusion under Amount A of Pillar One.
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On April 14 the Dutch Minister of Finance sent her report of the Eurogroup and Ecofin Council that took place on April 4-5, 2022 to the Dutch House of Representatives. Obviously several subjects were discussed during these 2 days of meetings. One of these being the proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. With respect to the discussions that took place in this respect the report of the Dutch Minister of Finance states the following:
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Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties.
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On April 12, 2022 the OECD together with Brazil's Receita Federal (RFB) (The Brazilian Federal Revenue Service) held a joint high-level event on April 12, 2022 in Brasília to present the key features of Brazil’s proposed new transfer pricing system.
Read more: Brazil and the OECD work together to align Brazil's transfer pricing rules to the...
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On March 14, 2022, the OECD launched a public consultation on the Implementation Framework. Ahead of the virtual public consultation meeting in this respect that will be held on April 25, 2022 the OECD has now published the responses it received on its request for input.
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On April 7, 2022, on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-333/20, Berlin Chemie A. Menarini SRL versus Administraţia Fiscală pentru Contribuabili Mijlocii Bucureşti – Direcţia Generală Regională a Finanţelor Publice Bucureşti with Berlin Chemie AG as intervener, (ECLI:EU:C:2022:291), was published. The question to be answered is whether in the underlying case the German shareholder has a fixed establishment for VAT purposes in the country of its subsidiary (Romania).
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On April 7, 2022, on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-342/20, A SCPI with Veronsaajien oikeudenvalvontayksikkö as interested party, (ECLI:EU:C:2022:276), was published.
Introduction
This request for a preliminary ruling concerns the interpretation of Articles 49, 63 and 65 TFEU.
The request has been made in proceedings brought by A SCPI, a company incorporated under French law, concerning a preliminary decision by the Verohallinto (tax authority, Finland) of 13 June 2019 on the taxation of rental income and the profits from the disposal of immovable property situated in Finland and of shares in companies owning immovable property situated in Finland which were received by A in that Member State during the 2019 and 2020 tax years (‘the decision of 13 June 2019’).
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On April 7, 2022, on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Emiliou in Case C-696/20, B. versus Dyrektor Izby Skarbowej w W., (ECLI:EU:C:2022:289), was published. The case is interesting because it shows the potential VAT complications to which an efficient supply chain might lead.
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Following the release of the Global Anti-Base Erosion (GloBE) Rules as part of a landmark agreement on a two-pillar solution and the related Commentary, the OECD/G20 Inclusive Framework on BEPS will develop an Implementation Framework to support tax authorities in the implementation and administration of the GloBE Rules. As the first step in this process, the Inclusive Framework invited input from stakeholders on the matters that need to be addressed as part of the Implementation Framework. This public consultation meeting will discuss the input provided and consider the mechanisms to put in place in order to ensure that tax administrations and MNEs can implement and apply the GloBE Rules in a consistent and co-ordinated manner.
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