5. The Presidency will aim at reaching agreement during the next months on the following EU-BEPS work items: A. Interest and Royalties Directive (IRD) 6. In June 2015, the Latvian Presidency proposed a split of the proposal concentrating work first on the insertion of a anti-abuse provision similar to the one in the PSD (Articles 1(2) to 1(4)

2018-04-12

Se hela listan på skatteverket.se Se hela listan på skatteverket.se Besides providing a comprehensive technical analysis of the EU Anti-Tax Avoidance Directive (ATAD), this book offers insight on selected issues connected with the OECD Base Erosion and Profit Shifting (BEPS) Project that are important for predicting its possible impact, including on relations with non-EU Member States. The Directive is fully compatible with BEPS. It has the added advantage of being legally binding and ensuring that all Member States apply the same measures for intermediaries. In addition, the EU provisions will also ensure that the reported information on cross-border arrangements is automatically exchanged between Member States. 2016.

May 2, 2019 Since the beginning of the OECD BEPS project, there has been both as regards to the impact of the EU anti-tax avoidance directives ("ATAD I Aug 21, 2017 With BEPS measures being implemented in the BEPS directives into more than 2,000 tax further strengthened by Council Directive (EU). is (or should be) sensitive to BEPS, it adds another layer of rules and regulations that need to DebevoiseWhat You Need to Know About Structuring Your Fund in the BEPS Era DebevoiseAnalysis - BEPS Action 6 and Private Equity Jun 1, 2016 Read "The EU Anti Tax Avoidance Package: Moving Ahead of BEPS?, Intertax" on DeepDyve, the largest online rental service for scholarly Sep 30, 2016 OECD BEPS Action Plan: moving from talk to action in the European EU ATA Directive and EU Code of Conduct — inbound profit transfers. Jun 28, 2017 Next to the OECD, also the European Commission would like a statement in the overall discussion on tax avoidance and aggressive tax planning. Implementation of the recommendation via EU or national legislative actions This directive is also known as ATAD or Anti-BEPS Directive and was issued on Learn more about pressure equipment directive 2014/68/EU and how it impacts your products. Schedule your consultation with Obelis' EU compliance experts. Following the OECDs final proposals on permanent establishments (PE), there is a growing need for multinational groups to assess where their PE risks might Mar 28, 2019 European countries face many issues that the BEPS project was intended to The project was named Anti Tax Avoidance Directive (ATAD).

Keywords: GAAR, abuse, tax avoidance, BEPS, principal purpose test, legal certainty 1 Introduction The EU has also adopted legally binding anti-tax avoidance measures targeting hybrid mismatches (BEPS Action 2), interest deductions (BEPS Action 4), and controlled foreign companies (BEPS Action 3) and has added EU-specific rules on exit taxation and general anti-abuse. 2 These measures are to be phased in over the period from 2019 to 2022, and the EU and OECD are now both discussing further On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or "Anti-BEPS" Directive. The Draft Directive proposes anti-tax avoidance rules in six specific areas, which are intended to be implemented by each EU Member State.

This Directive aims to achieve a balance between the need for a certain degree of uniformity in implementing the BEPS outputs across the EU and Member States' needs to accommodate the special features of their tax systems within these new rules.

In June 2015, the Latvian Presidency proposed a split of the proposal concentrating work first on the insertion of a anti-abuse provision similar to the one in the PSD (Articles 1(2) to 1(4) anti-BEPS measures. In the EU the European Commission will publish in early 2016 an EU anti-BEPS proposal which will implement important aspects of the OECD BEPS package.

OECD anti-BEPS recommendations not covered in the EU anti-BEPS directive will be left to the member states to implement. On December 11 2015, the draft text of the EU Anti-BEPS Directive discussed at the December ECOFIN meeting was made available to the public.

▷. ▷ Directive as well as the European Anti-Tax Avoidance Directive (for instance, the General Anti-Abuse Rule); and 4. The EU anti-tax avoidance directive can be said to have captured the essence of BEPS and made the implementation of these rules binding for the members of Project (BEPS) and the European Commission CRD IV Directive seek to tackle facilitating tax abuse, which the EU Directive on country-by-country reporting is Die EU-Richtlinie zur Bekämpfung von Steuervermeidungspraktiken. Die BEPS-Initiative stellt nicht nur ein Novum im Bereich der OECD-Steuerpolitik dar, The Swedish Parliament recently presented the bill ratifying an EU Directive regarding tax dispute resolution. The new rules proposed .

EU level and considered that EU directives should be, where appropriate, the preferred vehicle for implementing OECD BEPS conclusions at the EU level. It is important to consider that non-taxation could be evidence of an abusive purpose [indeed this is made explicit in double tax treaties post-BEPS Action 6 implementation of the MLI] but non-taxation alone should not be sufficient to deny directive/treaty benefits in circumstances where there is a substantive economic nexus between the counterparties (under a double taxation agreement) or The Directive provides broad rules but leaves the specific implementation and details up to the different EU Member States.
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att EU tar BEPS seriöst samt att det är en hård uppföljning på Proposal for a Council Directive amending Directive (EU) 2016/1164 as regards hybrid implementation of the BEPS-project. Because of the av J Monsenego · Citerat av 1 — EU-länderna har – eller håller på – att imple- mentera de åtgärder som bestämts via EU-direktiv.

Working together in the OECD/G20 Inclusive Framework on BEPS, over 135 countries are implementing 15 Actions to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.
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The latest information on the OECD's Base Erosion and Profit Shifting (BEPS) actions and recommendations and the EU's Anti-Tax Avoidance Directive (ATAD) .

2016-02-09 · The first BEPS related action at EU level was to include a general anti-avoidance rule and a provision against hybrid mismatches in the EU Parent Subsidiary Directive. The proposed new Directive may be a first step towards a Common Consolidated Corporate Tax Base (CCCTB).