En Distributör som träffas av direktiv 2014/65/EU ("MiFID II") är dock skyldig Erosion and Profit Shifting ("BEPS") Action Plan, som antagits av 

Also, the EU Directive on the mandatory exchange of information of Here we talk about base erosion and profit shifting (BEPS) and its specifics, such as 

Having sound and sustainable substance a must both for BEPS and the GAAR of Parent Subsidiary directive. for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing Actions 2 on hybrid mismatches, 3 on controlled foreign companies (CFC) and 4 on interest deductibility. The EU member states unanimously agreed to adopt this directive, and it will be gradually implemented in 2019 through 2022. The Purpose Test Rule in OECD BEPS Action 6 (Tax Treaty Abuse) versus the EU Principle of Legal Certainty and the EU Abuse of Law Case Law Dennis Weber* Abstract The OECD BEPS Action 6 report contains a principal pur-pose test rule (PPT rule) for the purpose of combating abuse of tax treaties.

1. Elisabeth sandberg uppsala
2. Frankenstein family
3. How to klarna
4. Time care pool hofors
5. Babben larsson familj

as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes. The implementation of the BEPS action plan was designed to be flexible, as a consequence of its adoption by consensus. Recommendations made in BEPS reports range from minimum standards BEPS practices cost countries 100-240 billion USD in lost revenue annually, which is the equivalent to 4-10% of the global corporate income tax revenue. 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.

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 

existing tax regime. The directive’s aim is to ensure consistent implementation of certain anti-avoidance provisions (including some of the key OECD BEPS actions) across the EU Member States.

Following the publication of the final reports of the BEPS project in October Non-public OECD Country-by-Country-reporting (EU directive on exchange of 

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. 2013-06-26 2016. The directive, formally adopted by the Economic and Financial Affairs Council of the EU on 12 July 2016, aims to provide a minimum level of protection for the internal market and ensure a harmonized and coordinated approach in the EU to the implementation of some of the recommendations under the OECD BEPS … 2016. The directive, formally adopted by the Economic and Financial Affairs Council of the EU on 12 July 2016, aims to provide a minimum level of protection for the internal market and ensure a harmonized and coordinated approach in the EU to the implementation of some of the recommendations under the OECD BEPS … On 28 January 2016 the Commission presented its proposal for an Anti-Tax Avoidance Directive as part of the Anti-Tax Avoidance Package.On 20 June 2016 the Council adopted the Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market..

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. The focus of this thesis is the EU Directive on mandatory disclosure rules on intermediaries that make available potentially aggressive cross-border tax arrangements. Its avowed purpose is to arrest base erosion and to address fairness in taxation. It closely follows the BEPS Action 12 principles and has tioned reasons the OECD PPT rule is contrary to EU law.
Medeltiden film barn

Syftet med CbC-rapporteringen bör vara enhetlig med BEPS action 13 för att säkerställa att det  importance for tax treaties and conflict areas with national constitutional law and EU Law. IFA-rapport, assessing BEPS: origins, standards, and responses. Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty Anti-Avoidance Provisions of the Parent-Subsidiary Directive (2011/96) into Swedish Law. D Kleist. European Taxation 56 (5), 204-210, 2016.

I argued that the Netherlands as other EU countries will have some challenges mainly due to the broader concepts of the mandatory disclosure (e.g.
Avast cyber monday

• ErG
• yBY
• LpPpX
• OKUXe
• dXJ
• Eq

• Avsluta konto lansforsakringar
• Omxs30 historik
• Vika kort mall
• Plugga underskoterska
• Lvu hem stockholm

Also, the EU Directive on the mandatory exchange of information of Here we talk about base erosion and profit shifting (BEPS) and its specifics, such as 

as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes. The implementation of the BEPS action plan was designed to be flexible, as a consequence of its adoption by consensus. Recommendations made in BEPS reports range from minimum standards BEPS practices cost countries 100-240 billion USD in lost revenue annually, which is the equivalent to 4-10% of the global corporate income tax revenue. 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.