RSM Global

Tax

UK cuts corporate tax rate again – to 18% by 2020

13 July 2015
The UK government announced yesterday that the main rate of UK corporation tax will be cut to 18% by 2020. It is currently 20% for the 2015 financial year which is the joint-lowest rate in the G20 group of countries. It will be reduced to 19% for the financial years 2017, 2018 and 2019 and then to 18% for 2020. 

Europe: New developments on the CCCTB

15 June 2015
On 27 May 2015, the European Commission held an orientation debate on how to develop a fairer and more efficient corporate tax system. Vice-President Dombrovskis of the European Commission held a speech afterwards to point out the main topics that were discussed:

Slovakia: New Transfer Pricing documentation guidelines published

15 June 2015
On 26 May 2015, the Ministry of Finance published new guidelines on transfer pricing documentation requirements. The Guideline will apply as of 1 January 2015 and replaces the previous guidelines of October 2014.

Europe: European Commission adopts the fourth Anti Money Laundering Directive

15 June 2015
On 20 May 2015, the members of the European Parliament adopted rules to combat money laundering and terrorist financing. This is one of the key actions in the European Security Agenda that was announced last month (28 April 2015).

OECD: OECD releases public comments received on discussion drafts on cost contribution arrangements of BEPS – Action 8

15 June 2015
On 1 June 2015, the OECD published the comments it has received on this discussion draft. In the past, the OECD had invited comments from interested parties on a discussion draft on revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements (work that relates to Action 8 of the OECD’s BEPS Action plan).

Germany/Netherlands: Treaty between Germany and Netherlands – details

15 June 2015
On 15 May 2015, the Netherlands ratified the Germany–Netherlands Income Tax Treaty 2012. This new treaty will replace the Germany–Netherlands Income and Capital Tax Treaty of 1959. The Treaty is in line with the OECD Model tax treaty. The maximum withholding tax rates included in the treaty are:

Europe: European Commission publishes strategy on the Digital Single Market

4 June 2015
The European Commission (EC) published its strategy on the Digital Single Market on 6 May 2015. The strategy includes 16 initiatives to be delivered by the end of 2016 and is built on three pillars: Access, Environment and Economy & Society.

Netherlands/OECD: Impact of changes of OECD Model Commentary with respect to the articles 15 and 17

4 June 2015
On 23 April 2015, clarification on the impact of the changes of the OECD Model commentary on articles 15 and 17 was published in a special Decree (effective 2 May 2015). The Decree provides guidance with respect to termination payments and on the interpretation of the term 'personal activities' of artist and sportsmen.  

Macedonia: Changes to the Corporate Income Tax law

4 June 2015
According to the last changes on the Corporate Income Tax law (Official Gazette of the Republic of Macedonia no. 112/14 from 25/07/2014), the obligation for paying corporate income tax (CIT) on net income is restored as from the fiscal year 2014. The CIT rate remains 10%.

Europe OECD: The OECD published the revised discussion draft on Action 7

4 June 2015
On 15 May 2015, the OECD released a revised discussion draft on Action 7. The revision is a follow-up to the discussion draft on Action 7 of 31 October 2014, which addressed a number of PE avoidance strategies and potential strategies to deal with these.

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