INTERNATIONAL TAX PLAZA - Qualification of legal entities

List of articles in category International taxation
Title	Published Date
Position paper of a knowledge group of the Dutch tax authorities: “A notional Brazilian withholding tax (tax sparing credit) cannot be deducted as costs in the Netherlands”	30 June 2023
Position paper of a knowledge group of the Dutch tax authorities regarding the settlement of German withholding tax withheld under the Dutch-German DTA over interest received on a mezzanine loan	25 June 2023
Position paper of a knowledge group of the Dutch tax authorities on the question whether assigned parking locations in relation to the rental of means of transport qualify as a PE?	30 May 2023
Position paper of a knowledge group of the Dutch tax authorities on whether the Interest and Royalties Directive applies in a certain situation	29 May 2023
Position paper of the Dutch tax authorities’ knowledge group on production costs that have been amortized at once and the second limit for the credit method to avoid double taxation	23 May 2023
Position paper of a knowledge group of the Dutch tax authorities regarding non-deductible interest expenses and the second limit for the credit method to avoid double taxation	22 May 2023

INTERESTING ARTICLES

Mutual agreement on the implementation of the arbitration process pursuant to Article 25, Paragraph 5 of the Dutch-Swiss DTA published in the Dutch State Gazette
The Irish Department of Finance published a Roadmap for the Introduction of a Participation Exemption in the Irish Corporation Tax and opened a public technical consultation
The General Court of the EU again rules the Belgian excess profit scheme to constitute illegal State Aid
The OECD published the comments it received on its public consultation of July 17, 2023 regarding Amount B of Pillar One
The European Commission released proposals for a BEFIT-Directive and a Council Directive on transfer pricing
During the IF meeting of July 10-12 the Netherlands advocated for international agreements on the taxation of so-called high net worth individuals
The New Zealand Government has introduced a Draft Digital Services Tax Bill into the House
The Irish Department of Finance has published its Annual Taxation Report 2023
Tunisia deposited its instrument of ratification for the MLI
The German Federal Cabinet passed a draft law to implement the EU Minimum Taxation Directive
The District Court of Luxembourg (Belgium) lodged an interesting request for a preliminary ruling regarding the conditions authorities can set for a MAP to be finalized
The independent Scientific Advisory Board to the German Federal Ministry of Finance considers the proposed DEBRA-Directive not the right way forward
Hoe de uiterste indiendatum van een beroep tegen o.a. een EU-Richtlijn bij het Gerecht van de EU moet worden berekend
Fugro lodged an action with the General Court of the EU to partially annul the EU Pillar 2 Directive