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Op 29 juli 2022 is in de Staatscourant van het Koninkrijk der Nederlanden een besluit van de staatssecretaris om tijdelijk Leidraad Invordering 2008 aan te passen ten einde de totstandkoming van minnelijke saneringsakkoorden van ondernemers te bevorderen gepubliceerd (Besluit van 25 juli 2022, nr. 2022-196575). De wijzigingen gaan in op 1 augustus 2022 en blijven van kracht tot 1 oktober 2023.
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On July 29, 2022 the Opinion of the European Economic and Social Committee on the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (COM(2021) 823 final — 2021/0433 (CNS)) was published in the Official Journal of the European Union.
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On July 29, 2022 the Opinion of the European Economic and Social Committee (EESC) on the Proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (COM(2021) 565 final — 2021/0434 (CNS)) was published in the Official Journal of the European Union.
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On July 22, 2022 a very interesting opinion of Dutch Advocate General Wattel was published on the website of the Dutch courts. In the underlying case the the Dutch Supreme Court is asked to answer the question if and under which conditions a so-called fiscal unity decree that was incorrectly issued by a Dutch tax inspector can be revised or withdrawn.
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On July 20, 2022 the UK Government released draft legislation introducing new transfer pricing documentation requirements for large multinational businesses operating in the UK. Based on the new legislation these large multinational businesses that are operating in the UK will be required to retain, and produce upon request, a master file, a local file and a summary audit trail. This measure will apply to businesses with accounting periods commencing on or after April 1, 2023.
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On July 25, 2022 the Inland Revenue Authority of Singapore (IRAS) published a high-level overview of which cost are deductible and which costs are non-deductible for a Singaporean Investment Holding Companies. In this respect the term investment holding company refers to a company that owns investments such as properties and shares for long term investment and derives investment income ('non-trade income') such as dividend, interest or rental income. The company's principal activity is that of investment holding.
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On July 21, 2022 we already reported that Her Majesty’s Treasury (HM Treasury) published the Summary of Responses to its public consultation on implementing Pillar 2, of the OECD’s Two-Pillar solution in the UK. On July 20, 2022 the UK Government also released Draft legislation to implement Pillar 2 of the OECD’s Two-Pillar solution in the UK.
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On July 21, 2022 Her Majesty’s Treasury (HM Treasury) published the Summary of Responses to its public consultation on implementing Pillar 2, of the OECD’s Two-Pillar solution. The document summarises the returns received to the consultation on implementing Pillar 2 in the UK, and sets out the government’s response to the themes raised.
The consultation period ran from January 11, 2022 to April 4, 2022. A total of 51 written responses were submitted to the consultation. In the press release in which the publication of the Summary of Responses was published the HM Treasury states that the government welcomes further representations until September 14, 2022.
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Op 15 juli 2022 zijn op de website van de rechtspraak 2 arresten van de Hoge Raad in 2 aparte zaken gepubliceerd. In beide zaken is sprake van een externe acquisitie waarbij (een deel van de) target na de acquisitie wordt gevoegd in de fiscale eenheid van de Nederlandse overnemer. De Nederlandse overnemers zijn dochtervennootschappen van Luxemburgse vennootschappen. Om de overname te financieren hebben de Nederlandse vennootschappen aandeelhoudersleningen gekregen van hun Luxemburgse aandeelhouders. Deze Luxemburgse vennootschappen hebben op hun beurt zgn Preferred Equity Certificates (PECs) uitgegeven.
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This story started in June 2020, when Unilever announced that it intended to move the tax residency form its worldwide head office from Rotterdam to the UK. However, it got an extra boost when on November 15, 2021, Shell announced that it was seeking shareholder approval to simplify its corporate structure and that it intended to move its tax residency to the UK. To many in the Netherlands this announcement came as a shock. Quickly 2 camps were formed. Since it was assumed that the Dutch dividend withholding tax and the absence of such tax in the United Kingdom was one of, if not, the main reason that Unilever and Shell moved their worldwide head offices from the Netherlands to the UK, one camp pled for a complete abolishment of the Dutch dividend withholding tax. The other camp led by the Greens (GroenLinks) pled for the introduction of a new exit levy that would keep multinationals from moving the tax residency of their headquarters out of the Netherlands.
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