The Resource BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective

BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective

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BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective
Title
BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective
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Language
eng
Summary
In recent years, concerns have been growing over base erosion and profit shifting (BEPS) by multinational enterprises (MNEs). In this respect, the OECD published a 2013 report, followed by an action plan to address BEPS. More or less in parallel with the OECD initiatives, European Union (EU) proposals to combat tax fraud and tax evasion within the EU were published. Following on from the OECD and EU action plans, in September 2014, the OECD published a series of (interim) reports with deliverables on several action points and the Council of the EU adopted an amendment to the EU Parent Subsidiary Directive. Together, the OECD and the EU propose a wide range of international taxation measures, which are likely to affect a broad range of taxpayers including not only MNEs, but, also, for example, small- and medium-sized enterprises (SMEs) and asset managers. The first part of this article examines unilateral initiatives taken by the Dutch government in respect of treaty abuse, substance and exchange of information, which are, to a certain extent, inspired by the BEPS Action Plan. Some of these initiatives led to new Dutch legislation effective from 1 January 2014. In the second part of this article, the authors examine developments with regard to hybrid mismatches within the context of the EU. As a result of an adopted amendment to the Directive concerning hybrid mismatches on 8 July 2014, the Netherlands must make an amendment to its participation exemption regime by 31 December 2015
Citation source
In: International tax journal. - Chicago. - Vol. 40 (2014),
http://library.link/vocab/creatorName
  • Flipsen, P.H.M
  • Duteweert, P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • BEPS Action Plan
  • mutual assistance
  • Parent-Subsidiary Directive
  • income classification
  • hybrid financial instrument
  • participation exemption
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BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective
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Publication
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BEPS developments and EU Parent Subsidiary Directive changes analyzed from a Dutch perspective
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