Netherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MoreAustralia: ATO issues draft schedule concerning cross border related party financing arrangements
On 1 August 2018, the Australian Taxation Office (ATO) issued a draft Schedule 2 to PCG 2017/4 for public consultation. This guidance addresses the ATO’s compliance approach to taxation issues associated with cross border related party
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MoreBelgium issues a draft bill to introduce some tax measures
On 11 June 2018, a draft bill was submitted to the parliament to complete and amend the corporate income tax reform of 2017. The bill contains a new anti-abuse provision for notional interest deduction (NID) and clarifies that the reduction of
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreUK: Consultation on conditionality measures to combat hidden economy
On 8 December 2017 HMRC published a consultation document entitled Tackling the hidden economy: public sector licensing. The document looks at measures that make compliance with tax obligations a condition of obtaining certain licenses and introduce
See MoreGreece: VAT compliant receipts to fight fraud
The Government has announced a monthly lottery on the basis of VAT compliant receipts issued to consumers for trying to reduce VAT fraud. From the last of October, every single VAT receipt issued in the country will display a unique number, which
See MorePoland: A new version of a draft bill to amend corporate income tax law
Recently, a new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual income tax law) was submitted to the parliament. The amendment will most likely come into effect on 1 January 2018. Main changes
See MoreCanada: CRA delays implementation of advantage rules
The Canada Revenue Agency (CRA) announced that the proposed implementation date for applying the advantage tax rules to investment management fees will be delayed until January 1, 2019. The rule could tax investment management fees paid outside of
See MoreItaly: New anti-avoidance measures under the “allowance for corporate equity”
In Italy, a new decree which was published in the official gazette on 11 August 2017 modifies the existing anti-avoidance rules under the “allowance for corporate equity” regime in such a way that duplications of the tax benefit within a group
See MoreUK: Second Finance Bill of 2017 published
On 8 September 2017 the UK government published the second Finance Bill of 2017. This second Finance Bill was necessary because not all the legislative changes announced in the autumn statement 2016 and budget proposals for 2017 could be included in
See MoreIreland publishes a report on review of Corporation Tax Code
On 12 September 2017, the Minister for Finance and Public Expenditure & Reform, Mr. Paschal Donohoe T.D., has published the Review of Ireland’s Corporation Tax Code, undertaken by Mr. Seamus Coffey. Mr. Coffey was appointed as an independent
See MoreOECD: Further guidance on CbC reports
Further guidance has been issued by the OECD's Inclusive Framework on BEPS in relation to the implementation and operation of Country-by-Country (CbC) reporting under Action 13 of the project on base erosion and profit shifting (BEPS). This latest
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