News Europe
The Netherlands Consulting on New Tax Group Regime
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June 20th, 2019
The Netherlands Ministry of Finance has announced the launch of a public consultation on the design of a new corporate tax group (consolidation) regime to replace the current fiscal unity regime, which was recently amended by emergency repair measures as a result of compatibility issues with EU law.
Background .
ECOFIN Removes Dominica From EU Non-Cooperative List
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June 20th, 2019
The Economic and Financial Affairs (ECOFIN) Council decided to further amend the non-cooperative list by removing Dominica from the list.
Current Non-Cooperative Jurisdiction List
Ten EU States Considering German Plan For .2% Tax On Purchases Stock In EU Headquartered Companies
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June 18th, 2019
Financial transaction tax initiated by the German government was under siege, until the European Union finance ministers recently confirmed that the proposal close to be agreed as the minister has discussed the issue on the implementation of 0.2% tax on shares.
Background .
Protocol Signed To Amend The Tax Treaty Between The Netherlands And Switzerland
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June 13th, 2019
The Netherlands has signed a protocol to amend the old tax treaty between the Netherlands and Switzerland. New agreements have been made against tax avoidance.
The Netherlands Establishes Expert Commission To Examine How To Make Multinational Taxation More Fair
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June 13th, 2019
The Dutch government issued an inquiry on how to make multinationals pay their fair share of tax, after public criticism that the government reforms do not go far enough. The government plans to establish an expert commission to examine such cases.
Dutch Supreme Court Rules Non-Continuation Requirement in Liquidation Loss Scheme
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June 11th, 2019
The Dutch Supreme Court ruled on the assessment procedure on non-continuation in liquidation loss schemes. The judge was of the opinion that the affiliation of the continuing company should be assessed when the liquidation is completed.
Finnish Government Introduces Tax Avoidance Measures In Its Tax Plan
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June 6th, 2019
Finland's newly formed center-left government is reportedly planning a number of tax measures to raise an addition EUR 730 million in tax revenue to fund increased spending. The government is also studying possible measures to reduce international tax planning and avoidance, broaden the corporate tax base, and tax dividends and real estate gains of foreign funds and other exempt entities.
European Commission Asks Harmful Member States To Change Tax Practices
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June 6th, 2019
The European Commission has asked the potentially tax aggressive countries such as Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands to address features of their tax system that may facilitate aggressive tax planning. The request was followed a recommendation report to change tax practices.
US Tech Giant Lobbied Ireland To Use Digital Tax As Tax Credit Against Irish Profit
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June 4th, 2019
Facebook Inc. Senior Executives have conveyed their opinion to Ireland’s minister of finance in January about the possibility of offsetting proposed EU digital services taxes against the company’s Irish corporate tax liability.
Background .
Cyprus Drafting Legislation for New Transfer Pricing Regime
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May 31st, 2019
The Cypriotic Ministry of Finance is reportedly finalizing draft legislation for the introduction of a new transfer pricing regime. The regime is to be in line with the latest OECD transfer pricing guidelines.
Ireland To Open To International Tax Changes
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May 28th, 2019
The Ministry of Finance of Ireland, Paschal Donohoe suggests that Ireland should consider a broader concept of how companies are taxed in the modern digitalized world, setting out his country’s stall in a debate that is key to its economy.
Ireland’s Reform Agenda .
U.K. GAAR Advisory Panel Issues Opinion On Tax Avoidance Scheme
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May 23rd, 2019
The General Anti-Abuse Rule (GAAR) Advisory Panel has determined that a disguised remuneration scheme involving employee rewards linked to a secondhand bond is abusive tax avoidance, effectively siding with HM Revenue & Customs.
Objective .
Dutch Tax Storm Hits US-Based Oil Company, Dutch Parliament To Hold Hearings
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May 23rd, 2019
Royal Dutch Shell revealed in 2018 only its gas subsidiary NAM paid corporate tax in the Netherlands, where it is headquartered, following Dutch parliamentary demands that it attends a hearing on tax avoidance.
Background .
Switzerland Approves Corporate-Tax Overhaul
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May 21st, 2019
Switzerland approved the Federal Act on Tax Reform with 64.4 percent of the population voting in favour of the project proposed by the Swiss government.
Norwegian Tribunal Adopts Profit Attribution Principles To Allocate Profit For PE
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May 16th, 2019
Norway's Tax Appeals Board was published decision concerning the allocation of costs to a permanent establishment in Norway. In particular, the decision addresses whether a deduction may be granted for the use of the parent company's employees and assets in determining taxable income of a permanent establishment.
Greens/EFA group in the EU Parliament Launches Tax Plans For 2019-2024
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May 16th, 2019
On 14 May 2019, the Greens/European Free Alliance (EFA) political group announced the launch of a 10-point plan for tax justice in the European Union, which will form part of its core demands for the coming legislative period in the European Parliament. The Greens/EFA Group has already been at the forefront of driving demands to combat excessive tax avoidance, tax evasion and money laundering in Europe.
France-Based Luxury Group Announces Settlement with Italy on PE and Transfer Pricing Issues
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May 14th, 2019
France-based luxury group Kering has reached a settlement with the Italian Revenue Agency concerning its Swiss subsidiary, Luxury Goods International S.A. (LGI), and concluded that the claims raised during the tax audit regard both the existence of a permanent establishment in Italy in the period 2011-2017 with the associated profits, and the transfer prices applied by LGI in the same period with its related party Guccio Gucci S.
EU Seeks Consensus On Digital Tax
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May 9th, 2019
The EU Tax Commissioner highlighted that it is essential for the European Union that any global agreement on international corporate tax reform also fits the particular needs and situations of member states and the EU as a whole. This means shaping a solution that both respects the EU single market rules and benefits the single market.
Dutch Court Allows Interest Deductions On A Hybrid Loan
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May 9th, 2019
The Dutch appellate published the decision on transfer pricing adjustments to hybrid loan. Based on the court decision, the Dutch appellate was allowing interest deductions on a hybrid intragroup debt instrument, rejecting the tax administration’s stance that the deductions were barred by transfer pricing and financial instrument characterization rules.
Ireland Is Forecasted To Lose €3bn If OECD Reforms Passed
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May 7th, 2019
During the conference held by Ministry of Finance and the International Monetary Fund (IMF) estimates that international tax reform could cost the State €2-€3bn in annual corporate tax revenues in the years ahead. The estimation relate to changes expected to emerge from an OECD reform process due to conclude next year.

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