The EC on Monday 14 December confirmed that it has requested more information in its ongoing investigation into whether Irish tax rulings granted to Apple constituted illegal state aid.
The Dutch ministry of finance has issued a statement confirming that the Netherlands will be appealing the European Commission’s ruling in October that the country provided state aid to Starbucks Manufacturing EMEA BV.
HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.
Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.
The OECD invites comments by 12 June 2015 on a new discussion draft for action 7 of the BEPS action plan (see www.bit.ly/1HmYCwj). This reflects comments received on the first discussion draft published in October 2014.
Sean McGinness (The VAT Consultancy) answers a query on VAT on cross-border business establishments
Deloitte has reported that HMRC has started to issue letters to companies affected by the approach it has decided to take on pre-2006 cross-border group relief claims in the light of the CJEU decision taken in February, asking them to consider withdrawing some of the claims they have made.
The European Commission’s VAT Expert Group (VEG) has adopted an opinion on the EU cross-border rulings (CBR).
The OECD has published a discussion draft on action 12 (mandatory disclosure rules) of the BEPS action plan for consultation. The discussion draft:
The EC has announced that its cross-border VAT rulings trial, which started with its first test case on 1 June 2013, has been extended to 30 September 2018.