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Read moreExpertsNews & KnowledgeLatest NewsBrochuresNewslettersNews & Knowledge Welcome to WTS Global Insights. Here you will find news and updates from our worldwide network. Read moreHot TopicsPillar TwoPillar Two TeamPillar Two - Implementation Status WordwideFIT for CBAMTax Sustainability IndexViDA - VAT in the Digital AgeEU WHT ReclaimsplAIgroundProSports Tax GroupHot Topics Overview of the current "Hot Topics" in the tax industry and how we can support with individual questions. Read moreCulture & CareerCulture and LeadershipDiversityWTS Global AcademyCareerCulture and Leadership WE PLAY DIFFERENT. Read moreCareer Join the game-changers. Read moreLocationsSearchHomeServicesappointed for the Belgian list of independent persons of standing who will form part of the Advisory Commission for dispute resolutionInés BlancoHereWTS Global DAC 6 Executive SummaryCouncil Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangementsCouncil Directive 2011/16/EU  of 15 February 211 on administrative cooperation in the field of taxation (consolidated text)Proposal for a Council Directive amending Directive 2011/16/EU deferring certain time limits for the filing and exchange of informationDAC 6 - Reporting obligations for tax planningProposal of DAC 7hereCouncil Directive 2017/1852 of 10 October 2017appointed for the Belgian list of independent persons of standing who will form part of the Advisory Commission.Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European UnionCommission Implementing Regulation (EU) 2019/652 of 24 April 2019 laying down standard Rules of Functioning for the Advisory Commission or Alternative Dispute Resolution Commission and a standard form for the communication of information concerning publicity of the final decision in accordance with Council Directive (EU) 2017/1852 Nigeria: Navigating a Tax Dispute ResolutionImplementation of the EU Directive on Tax Dispute Resolution Mechanisms in AustriaThe Spanish government has recently published the draft State General Budget for 2023 which includes several relevant tax modifications.  Key tax measures introduced by Spain’s General Budget for 2023 Read moreOn October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’ (news item). This draft bill is open for public consultation until December 5, 2022. The Netherlands: Draft bill to implement Pillar Two rules Read moreAn Austrian Fiscal Court (BFG) decision, which referred to ECJ case law, has held that the Austrian group tax regime’s limitations conflict with EU fundamental freedoms. If the BFG ruling is confirmed by the Austrian Supreme Administrative Court (VwGH), then a substantial easing in forming Austrian tax groups within multinational enterprises could be ahead. Austria: Are lower entry barriers on the horizon for multinational groups in the Austrian group tax regime? Read moreThis newsflash describes the status and evolution of the tax treatment of dividends across the EU, including the legislative developments that are underway in certain Member States. Withholding tax on dividends - current status in some Member States Read moreOn 11 May 2022, the European Commission published a proposal for a Directive providing for a debt-equity bias reduction allowance (‘DEBRA’). This directive is part of the Commission’s proposed measures to support Europe’s recovery from the COVID-19 pandemic. A proposal for a Directive on debt-equity bias reduction allowance (DEBRA) Read moreOn 17 March 2022, the European Court of Justice (“ECJ”) has issued a preliminary ruling on Case C-545/19 (AllianzGI-Fonds AEVN) ECJ landmark decision in the case C-545/19 (AEVN) dated 17 March 2022 Read moreOn 15 March 2022, Ministers of the EU Economic and Financial Affairs Council (ECOFIN) failed to reach an agreement on the proposed Pillar Two Directive. While most Member States are supportive of the proposed Pillar Two Directive, Estonia, Malta, Poland and Sweden expressed reservation concerning certain issues. Poland blocks EU adoption of the Global anti-Base Erosion (GloBE) model rules Read moreOn 22 December the European Commission published a proposal for a Directive to prevent the misuse of shell entities in cross-border situations. The proposal contains model rules that should ensure that shell entities in the EU that have no or minimal substance are unable to benefit from certain tax advantages. The ATAD3 Directive -The crackdown on EU ‘Shell entities - ETLC Newsflash #27 Read moreAn important decision on the characterization of a permanent establishment in France has been rendered by the French Supreme Administrative Court (Conseil d’Etat) in the Conversant International Ltd case (CE, 11 December 2020, n° 420174). France: Continuation and end of the Conversant International Ltd case - Permanent establishment in the digital field Read moreThe Pillar Two Model Rules and the EU Directive proposal to implement them have been published. This initiative aims to ensure that from 2023, Multinational Enterprises (MNEs) will be subject to a 15% global minimum tax rate. Our WTS Global experts have written an overview to provide insight into this groundbreaking matter. OECD publishes Pillar Two Model Rules for Domestic Implementation of 15% Global Minimum Tax Read moreThe European Commission has started an initiative to introduce a common EU-wide system for withholding taxes on dividend or interest payments.  New EU system to avoid double taxation for withholding taxes Read moreThe French research tax credit (“CIR”) has undergone several changes recently, as a result of new French Supreme Court case law, the 2021 Finance Act and the updating of tax authorities guidelines. France: An overview of recent news regarding the research tax credit (CIR) Read moreThe Italian measures adopted in connection with the COVID-19 pandemic include specific rules concerning the Regional Tax on Production Activities (IRAP) payment. Covid-19 measures: waiver of the Italian regional tax on production activities Read moreOn 18 May 2021, the European Commission (“EC”) published its long-awaited Communication on Business Taxation for the 21st Century (the “Communication”). The European Commission’s view on business taxation in the 21st century - ETLC Newsflash #23 Read moreOn 12 May 2021, the EU General Court delivered two judgements relating to appeals made against the EU Commission’s decisions taken back in 2017 and 2018. EU General Court judgements: Engie received illegal state aid, Amazon did not - ETLC Newsflash #22 Read moreGermany’s highest tax court, the Bundesfinanzhof (BFH), has filed a preliminary ruling request to the Court of Justice of the EU (CJEU). The request comprises five questions relating to the concept of “final losses”.  The German Federal Tax Court has filed a preliminary ruling request on “final losses” - ETLC Newsflash #21 Read moreOn 16 March 2021, the CJEU upheld the European General Court’s judgments Commission vs. Poland and Commission vs. Hungary, which had ruled that the Polish tax on the retail sector and the Hungarian tax on advertisements did not infringe EU law on State aid.   CJEU rules that Hungarian and Polish progressive taxes on turnover do not violate EU State aid rules - ETLC Newsflash #20 Read moreThe European Commission has started infringement procedures in several countries of the EU arguing that their levying of withholding tax on investment income received by foreign insurance companies has resulted in an unequal treatment of these companies. EU Commission challenges Belgian and French (withholding) taxes on investment income received by foreign insurance companies - ETLC Newsflash #19 Read moreThe Portuguese withholding tax provisions consist of a difference in treatment between resident and non-resident investment funds, which has been brought before national courts and the ECJ. Some Portuguese courts have already ruled that there is indeed a breach of EU law. WHT applicable to dividends obtained in Portugal by EU investment funds: a breach of EU law? - ETLC Newsflash #18 Read moreThe recent ECJ decision of March 3rd, 2021 (case C-220/19, Promociones Oliva Park, S.L.) brings to an end the long-lasting controversy on the compatibility with EU Law of the Tax on the Value of Electricity Generation. The European Court of Justice endorses the Spanish tax on electricity generation - ETLC Newsflash #17 Read moreIn the Lexel case, the European Court of Justice concludes that the so-called “10% rule” of the former Swedish interest deduction limitation rules is incompatible with EU law The CJEU rules against the Swedish interest deduction limitation rules - ETLC Newsflash #16 Read moreContactAbout WTS GlobalAbout UsOur Supervisory BoardQuality, Process & Risk ManagementServicesCustomsFinancial ServicesGlobal MobilityIndirect TaxInternational Corporate TaxMergers & Acquisitions (M&A)Private Clients & Family OfficeSustainability & TaxTax Certainty & ControversyTax TechnologyTransfer Pricing & ValuationLatest NewsNews & KnowledgeBrochuresNewslettersNewsletter SubscriptionHot TopicsPillar TwoDigital Tax LawEuropean Tax LawCulture & CareerCompany InformationData ProtectionDisclaimer

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