Latest news & developments
OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
Summer is here – principles of student work
The summer holidays have started and both students and employers might still be looking for either a summer job or a student to temporarily join their team during the coming months. We would therefore like to reiterate the regulations and points of attention related to employing students. Definition of “student” In order to be considered
Revision of the Posting Directive approved
Following the positive vote by the European Parliament in May, the Council of the EU has now approved the revision of the Posting of Workers Directive 96/71/EC (“Posting Directive”) as well. The most significant changes included in this revision are the introduction of the concept of a “long-term posting” for postings exceeding 12 months (with
Update on pending changes to the German RETT regime for share deals
The heated debate on the tightening of the German RETT Act to expand the scope of this tax to include sales of less than 95% of the company’s share capital continued with a meeting of the Finance Ministers of the Federal States on 21 June 2018. Although no formal draft document is available yet, changes
OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
EU Commission finds that Luxembourg gave State aid to GDF Suez (now Engie)
On 20 June 2018 the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to GDF Suez group (now Engie) (“the Group”) in relation to the treatment of certain financing transactions. The EC considered that the Group received an
