May 2018  
ET Preview IBFD, Your Portal to
Cross-Border Tax Expertise
European Taxation
 
This free e-mail service informs you about the contents of the forthcoming edition of European Taxation.

Issue No. 5 - 2018 of the European Taxation is now available online.

Visit www.ibfd.org for more information about IBFD publications and services.

Archive | Subscribe to other Journal Previews

[*link.unsub('Unsubscribe)*]

IBFD
P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel: 31-20-554 0176
Fax: 31-20-622 8658
info@ibfd.org
www.ibfd.org



Other publications and courses available on Europe:

Text

Number 5 - 2018 contains the following:
ARTICLES
European Union

New Developments in International Administrative Assistance in the Recovery of Taxes

Ilse De Troyer

This article provides a comprehensive overview of recent EU developments concerning mutual assistance in the recovery of taxes.

Italy/International

The Italian Web Tax from a National and International Perspective

Piergiorgio Valente

To ensure taxation of digital business profits, Italy has introduced a web tax on digital transactions relating to a supply of services, sparking debate both domestically and internationally, since proposals are expected from the OECD and the European Union for coordinated solutions to the issue. This article provides an overview of questions that the Italian web tax has generated, concluding that Italy’s actions have set off alarm bells that should promote prompt cooperation internationally.

International

Anti-Abuse Notion of “Control over Intangible-Related Functions” is Beyond the Arm’s Length Principle

Andrea Musselli

This article takes the position that Example 17 (on intangibles) of the OECD Transfer Pricing Guidelines (2017), which focuses on the issue of control over a research activity and the relationship between control and entitlement to ownership of an intangible and the revenues it generates, is not grounded in theory or in empirical evidence under the arm’s length principle.

EU UPDATE
Commission

Adrián Grant Hap

Council

Adrián Grant Hap

Parliament

Adrián Grant Hap

WHAT'S GOING ON ...
Belgium

Belgium’s New Innovation Income Deduction Regime

Werner Heyvaert

The Law of 9 February 2017 has replaced Belgium’s patent income deduction regime with a BEPS-compliant innovation income deduction regime effective 1 July 2016. Up to 85% of qualifying innovation income is allowed as a tax deduction. The taxpayer’s innovation income is limited to innovation income that has a sufficient nexus to Belgium. Pursuant to the CIT Reform Act of 25 December 2017, effective 1 January 2020, the actual CIT Rate on qualifying innovation income can be as low as 3.75%.

Bulgaria
Corporate Tax Changes
Lubka Tzenova

This note discusses changes to the Corporate Income Tax Act in respect of the filing of tax returns, the repeal of the right to a deduction from annual corporate tax due, the provision of criminal records on the tax authorities’ own motion, State aid developments and amendments to the Accountancy Act relating to tax paid under the CITA. Finally, the note recaps a letter sent by the National Revenue Agency regarding evidencing expenses.

Iceland

New Developments in the Application of the Interest Deduction Limitation in Iceland

Vigdis Sigurvaldadottir

A new interest deduction limitation rule was introduced in Iceland on 13 October 2016, which limits the deduction of interest expenses to 30% of EBITDA. This note focuses on legislative changes made in 2017 with regard to the rules, as well as the conclusion of the Directorate of Internal Revenue that only gross interest expenses should be considered in determining the interest deduction limitation.

International
Symposium on Mandatory Disclosure
René Offermanns

In this note, the author reports on a symposium held on 8 February 2018 in The Hague on the impact of mandatory disclosure on both tax advisors and the tax authorities.

Romania

Implementation of the EU Anti-Tax Avoidance Directive (2016/1164)

Oana Popa

This note discusses implementation of four out of the five EU Anti-Tax Avoidance Directive (2016/1164) measures in the Romanian Tax Code.

OFFICIAL JOURNAL OF THE CONFÉDÉRATION FISCALE EUROPÉENNE