Tax Journal – International briefing for June

Tax Journal – International briefing for June

Chris Morgan’s latest summary of international developments.

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The main BEPS development this month has been the release of a discussion draft on a multilateral instrument. At the EU, there have been a number of developments around the proposed Anti-Tax Avoidance Directive. In the Netherlands, proposed changes to the innovation box have been released and proposals to change the dividend withholding tax rules for cooperatives are expected to be presented on Budget day. Details on the implementation of Italy’s new tax ruling procedure for substantial investments have been released. In Finland, there have been recent developments that could impact debt push down arrangements and proposed changes to time limits which could impact, in particular, overseas funds making claims for refunds of withholding tax.

In the latest of his regular articles for Tax Journal*, Chris Morgan rounds up recent international developments. This month’s article looks at:

  • The OECD discussion draft on a multilateral instrument to modify existing bilateral tax treaties in order to implement base erosion and profit shifting (BEPS) tax treaty measures;
  • The EU’s Anti-Tax Avoidance Directive;
  • Proposed changes to the Dutch ‘innovation box’ and dividend withholding tax rules for cooperatives;
  • Italy’s new tax ruling procedure;
  • Court decision in Finland on deductibility of interest allocated to Finnish branches of foreign companies; and
  • Finland proposes time limit changes for tax matters.

*First published in Tax Journal on 24 June 2016. Reproduced with permission.

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