Pillar Two – impact on the maritime industry
On December 20, 2021, the OECD published the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) report, involving 137 countries. This one-pager provides insights into specialists view on the impact of Pillar Two on the Maritime Industry.
Revenues EU ETS and CBAM for the EU?
On December 22, 2021, the European Commission published its proposal for the next generation of EU own resources. There are from a Tax Sustainability perspective two proposed new resources of revenue in relation to the EU budget.
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
FS Tax Newsletter | January 2020
Last year our first FS Tax Newsletter for 2019 discussed the CJEU judgment rendered in the Morgan Stanley case, concerning the right of a branch to recover input VAT if it (partially) provides support services to the head office in another EU Member State. We will be discussing in this newsletter a similar matter that has been presented to the CJEU for a preliminary ruling in the Bank of China case. We also discuss another case concerning the VAT position of fixed establishments. It seems that branches and VAT are still a hot topic in 2020.
FS Tax Newsletter | November 2019
In this edition we highlight the key aspects of the 2020 Tax Plan. We also focus on three important CJEU cases concerning the VAT payable on assignment of a debt recognized in enforcement proceedings, VAT and services related to the operation of ATMs and VAT on services provided by a head office to its fixed establishment. Finally, we would like to invite you to a seminar on the OECD BEPS 2.0 / Pillar Two consultation and to a roundtable for pension funds and asset managers (see points 5 and 6).