OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)
On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterprises with a revenue in excess of EUR 750 million.
European Commission’s response to the OECD Pillar 2 model rules
On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but have a broader scope that includes large-scale purely domestic groups.
FS Tax Newsletter | August 2020
In this edition of the FS Tax newsletter we discuss two important judgments by the Court of Justice of the European Union in VAT cases: firstly, in the A Oy case, the Court established that co-location services do not constitute the leasing of or service attributable to immovable property. Secondly, in the BlackRock case, the Court confirmed that the provision of a single management service is not partially VAT-exempt.
FS Tax Newsletter | June 2020
In this edition of the FS Tax Newsletter we address two developments initiated by the Dutch tax authorities: the further development of horizontal monitoring and the cancellation of rulings confirming the VAT exemption for investment management services provided to CLOs. We also discuss four other VAT-related subjects: an interesting judgment from the Court of Appeals Den Bosch regarding the VAT recovery methodology of a financial institution, the opinion of the Advocate General of the Court of Justice of the European Union on the VAT treatment of purchased investment management services that are used for both Special Investment Funds as well as non-Special Investment Funds, a judgment by the Noord-Holland District Court on the VAT position of a company pension fund, and recent developments with respect to the term ‘fixed establishment’ for VAT purposes
Brexit: right of UK citizens to reside in the Netherlands
On January 31, 2020 the United Kingdom left Europe. A withdrawal agreement (‘deal’) was negotiated under which UK citizens and their family members who lawfully resided in the Netherlands before the Brexit date or during the transitional period will retain their right to reside in the Netherlands. The transitional rules apply through to December 31, 2020. The arrangements in the withdrawal agreement apply to both UK citizens and any family members who are not EU nationals.
OECD Update: 'Unified Approach' promising for acceptance
On 31st of January, 2020, the OECD gave an update on the outline for a global taxation of multinationals: 'Unified Approach'. Jaap Reyneveld, partner at KPMG Meijburg & Co: “It looks like the 'Unified Approach' of the OECD has a good chance of being accepted on a global level. This will have an impact on both tech companies and more traditional multinationals."