Tax & Compliance Bulletin 54

EU: Member States could be candidates for blacklisting as non-cooperative jurisdictions from March 2020 according to a proposal by the Danish government supported by Germany, France, Spain, Austria and others.

DAC6 – EU Mandatory Disclosures for Intermediaries

6th Amendment to the EU Directive on Administrative Cooperation:-
DAC6 comes into effect on the 1st July 2020 and imposes reporting obligations on cross border arrangements (CBAs), relating to direct taxation, that contain at least one of the hallmarks listed in the Directive. VAT and other forms of indirect taxation are therefore excluded from the Directive.

DM Europe TAG Alliances Ranked 3rd Globally

DM Europe’s international alliance of independent accounting and professional services firms, TAG Alliances®, has been recognized by Accountancy Age as one of the top three accounting alliances in the world. This is the eighth consecutive year that TAG Alliances has been ranked in this elite position.

Tax & Compliance Bulletin 53

EU: Tax Policy Key to New European Green Deal:
The President of the European Commission Ursula von der Leyen presented her ambitious climate-change related policy proposal ‘New Green Deal’, under which every aspect of the EU economy will be re-evaluated to address the shortcomings of the European framework, which are compounded by the climate emergency. The European leaders endorsed the policy goal of making Europe a climate-neutral by 2050, with a dissenting opinion from Poland could not commit to this goal, as a result of which the EU leaders will re-evaluate the matter in June 2020.

Bulletin 52

OECD – As a follow-up of BEPS Action 13, the OECD /G20 Inclusive Framework on BEPS has released updated guidance on the implementation and operation of Country-by-Country Reporting (CbCR). The new guidance includes the treatment of dividends, the operation of local filing…

Bulletin 51

EU: The Council of the EU has reached an agreement on the amendments to the VAT Directive in relation to SMEs. The objective of the amendments is to reduce the administrative burden and compliance costs for SMES, and in particular addresses SMEs operating in a cross-border context.

Bulletin 50

EU’s Financial Affairs Council (ECOFIN) considered on 10 October further harmonisation of the EU Anti-Money Laundering (AML) regime by upgrading the present AML directives to a regulation, an EU law instrument which is directly enforceable in all EU Members states without further implementing acts at …

Bulletin 49

SWITZERLAND: European Union finance ministers agreed to white-list Switzerland as compliant with all required tax cooperation commitments. The United Arab Emirates has also been removed from the EU blacklist, having enacted satisfactory economic substance legislation. Nine jurisdictions remain on …

Bulletin 48

INTERNATIONAL TAXATION: The Organisation for Economic Co-operation and Development (OECD) has released a detailed work plan to develop a consensus solution to the tax challenges arising from the digitalisation of the global economy. The 129 countries participating in …

Bulletin 47

CRYPTOCURRENCIES: Social media company Facebook plans to launch its own virtual currency, GlobalCoin, next year. It will be used as a worldwide digital payments system, and will be available initially in around a dozen countries by the first quarter of …

Bulletin 46

BENEFICIAL OWNERSHIP: The UK Minister for the Commonwealth and the United Nations, Lord Ahmad, has assured British Overseas Territories (OTs) that they have until 2023 to establish publicly available registers of beneficial ownership, during which time the UK will be campaigning to have …

Bulletin 45

SPAIN: The European Commission has requested Spain to impose equal taxes on rental income received by resident and non-resident individuals. Landlords receive a 60 per cent tax exemption for renting their properties out as a tenant’s main residence, but non-resident individuals with real estate properties in …

Bulletin 44

IRELAND: The Irish government has again postponed its plans to revalue domestic property for the purposes of local property tax (LPT), this time from 1 November 2019 to 1 November 2020. Property prices have increased sharply but unevenly across the Republic of Ireland since the last valuation in …

Permanent Establishment

(1) For the purposes of this convention the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
(2) The term “permanent establishment” includes especially…