US: IRS Issued New Revenue Procedures on Competent Authority and Advance Pricing Agreement
The IRS has issued two revenue procedures on August 12, 2015 with details guidance to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement (APA) program. The proposed version of
See MoreECJ ruling on exemption from capital duty under the Capital Duty Directive
On 22 April 2015 the European Court of Justice (ECJ) delivered its ruling in the case of Drukarnia Multipress. Drukarnia was a Polish limited liability company that intended to carry out a conversion into a limited joint-stock partnership (SKA) and
See MoreECJ requested to give a preliminary ruling on pension surtax
The European Court of Justice (ECJ) was requested by Finland’s Supreme Administrative Court (KOH) on 6 March 2015 to give a preliminary ruling in respect of the pension surtax. Finland has imposed a surtax of 6% on large pensions since 2013. The
See MoreEU-Ukraine Association Agreement Ready To Ratify
The technical preparation of the EU-Ukraine Association Agreement for its subsequent ratification by parliament will be completed in the near future, the Ukrainian Foreign Ministry has said. Both sides will progressively establish a free trade area
See MoreRomania: Under pressure on VAT recovery process
Romania has formally requested by the European Commission to improve its Value Added Tax (VAT) recovery process. The caused for opinion from the European Commission, the step before proceedings at the European Court of Justice, states that the
See MoreEU Member States React To EU FTT Declaration
Some EU member states have commented on the intention of a number of member states to go ahead with the introduction of a financial transactions tax (FTT) under the EU’s enhanced cooperation provisions. The member states that are not participating
See MoreEU – European Bankers Warn Of FTT Fallout
The European Banking Federation (EBF) considers that the introduction of a financial transaction tax (FTT) by some European Union member states will create uncertainty for business in the whole EU. Even if the FTT is implemented by only some of the
See MoreEU Member States Criticized for Lack of Transparency in FTT
At the EU’s ECOFIN meeting of economic and financial ministers on 6 May 2014 a joint statement was issued by ten of the member states that are going ahead with the financial transactions tax (FTT) In all, eleven EU member states have decided to
See MoreGermany and the EU Agree Energy Tax Break Revision
Germany is being allowed by the European Commission to continue to give energy tax incentives to 65 sectors under the renewable energy tax rules. There has been a long discussion as to whether the measures constitute illegal state aid under EU
See MoreEU Tackles Single Market Tax Obstacles
The European Commission has begun two public consultations, on discriminatory tax rules that my affect the position of individuals in European Union (EU) member states. These consultations are aim to help efforts to take away tax obstacles to
See MoreEU: Court of Justice decision affecting US regulated investment companies
On 10 April 2014, the Court of Justice of the European Union (CJEU) ruled in case C-190/12 concerning the Emerging Markets Series of DFA Investment Trust Company. The CJEU held that barring a non-EU investment fund, in this case a US investment
See MoreLuxembourg supports revised Savings Tax Directive
The EU has adopted the revised Savings Tax Directive, strengthening the efforts to combat cross-border tax evasion by exchanging information on savings income. The revised text extends the scope of the Directive more entities and types of income
See MoreAustria: Information regarding intangible property and financial services
From 1st March 2014, interest and royalty payments to certain related parties are not deductible for tax purposes if the recipient corporation is not subject to tax due to an exemption; is subject to a nominal or specific tax rate of less than 10%
See MoreCzech Republic joins Convention and protocol on Mutual Administrative Assistance in Tax Matters
The multilateral Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 protocol, entered into force in respect of the Czech Republic on 1 February 2014. The Convention and the amending protocol generally apply in the
See MoreCroatia-Bill Ratifying Multilateral Tax Convention
The government of Croatia has sent a bill to parliament to ratify the Convention on Mutual Administrative Assistance in Tax Matters. This move forms part of the country's aims to fulfill its tax obligations on an international level. Croatia signed
See MoreEU: Uniform Customs Code effective from 1 May 2016
The European Commission has notified that the substantive provisions of the Uniform Customs Code have entered into force 30 October 2013, and will be effective from 1 May 2016. Until then, the Community Customs Code and its implementing provisions
See MoreEU: Royalties, license fees dutiable from 1 May 2016
The European Commission has pointed out that the process for determining the transaction value would be amended under the Uniform Customs Code (UCC), due to enter into force on 1 May 2016, resulting in royalties being more often included in the
See MoreEU – Forms for customs enforcement of IP rights
The European Commission has issued new forms which should be used from 1 January 2014 in order to ensure customs enforcement of intellectual property rights. The new implementing regulation that introduces such standard forms, and rules for
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