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On March 16, 2023 a virtual public consultation meeting on compliance and tax certainty aspects of global minimum tax was held. The meeting was held via zoom and for being able to participate one had to register upfront.
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On March 16, 2023 on the website of the Court of Justice of the European Union (CJEU) the opinion of Advocate General Collins in the joined Cases C-508/21 P (the European Commission versus Dansk Erhverv) and C-509/21 P (Interessengemeinschaft der Grenzhändler (IGG) Dansk Erhverv and the European Commission), ECLI:EU:C:2023:224, was published.
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On March 15, 2023 the United Mexican States has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (The BEPS Convention). The BEPS Convention will enter into force on July 1, 2023 for Mexico.
Read more: Mexico deposited its instrument for the ratification of the Multilateral BEPS Convention
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As a tax adviser I have never been a big fan of structures that include a dual resident entity and in general I would not advise a client to use dual residency in a structure. I might consider using a dual resident entity if the entity would have a certain minimum presence in the jurisdiction that it was relocated to and if next to that its board of directors would consists out of qualified experienced individuals of which a majority would be a residing in the jurisdiction to which the entity moved would want to move its (tax) residency. This to minimize the risk that tax authorities might question where the place of effective management of the entity is located. For the same reason I have never been a big fan of using trust offices or their employees as directors of group entities.
Read more: When dual residency and the use of a trust office turns into a tax adviser’s nightmare
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On March 9, 2023 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-239/22, État belge versus Promo 54 SA and Promo 54 SA versus État belge, ECLI:EU:C:2023:181, was published.
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On March 9, 2023 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-42/22, Generali Seguros SA (formerly Global – Companhia de Seguros, SA) versus Autoridade Tributária e Aduaneira, ECLI:EU:C:2023:183, was published.
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On March 3, 2023 the European Commission issued a press release announcing that it ordered has ordered Italy to recover illegal State aid granted to certain non-commercial entities in the form of a real estate tax exemption. This order is the latest development in a case that started already in 2010 (13 years ago). A case in which in 2012 the European Commission concluded that in this specific case, recovery would be absolutely impossible and that it therefore did not order Italy to recover the aid from the beneficiaries. A decision that was subsequently annulled by the Court of Justice of the European Union (CJEU) in 2018.
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On March 2, 2023 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-16/22, MS with other as parties Staatsanwaltschaft Graz and Finanzamt für Steuerstrafsachen und Steuerfahndung Düsseldorf, ECLI:EU:C:2023:148, was published.
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