The Tax Bulletin for 2017 gives an overview of the most significant tax developments that took place in our home markets, Belgium, Luxembourg, the Netherlands and Switzerland, in 2017. It also highlights the main legislative changes that have been announced in these countries for 2018, and offers insights into major EU and other international developments. The focus is on developments and changes that could have an impact on international businesses.
BEPS project picking up steam
So far this year, 71 countries have signed the Multilateral Instrument, which is part of the OECD's BEPS project. The Multilateral Instrument introduces new tax treaty provisions or modifies the operation of existing ones, and can thus be expected to impact MNEs.
Progress up ahead on the C(C)CTB
Next year there will be a further round of negotiations among EU Member States on the Common (Consolidated) Corporate Tax Base (C(C)CTB) proposals. The European Parliament's draft resolution calls for taxation of the digital economy to be taken into account. The policy debate that has been taking place within the EU and among the other industrialised economies on how to tax the digital economy could accelerate the adoption of compromise language on the C(C)CTB proposals.
Ringfencing the digital economy?
Tax policymakers have begun to believe that companies with a digital business model, such as US tech giants, have not been paying their fair share of corporate taxes, even as some progress has been made on the BEPS project. If no international consensus can be reached early next year, when an OECD report on the matter is due, the European Commission is expected to publish a legislative proposal on how best to tax the digital economy. It is still too early to tell whether there is enough political support for a tax regime that would only target digital companies. That said, the topic is clearly high on the agendas of both the EU and the OECD. As it would be difficult, if not impossible, to ringfence the digital economy for tax purposes, there is a possibility that such proposals, if adopted, could also impact the traditional economy.
New momentum for the Anti-Tax Avoidance Directive
It is expected that many, if not all, EU countries will come up with legislative proposals for the implementation of the Anti-Tax Avoidance Directive 2, which has been adopted with a view to neutralising hybrid mismatch structures involving non-EU countries.
A bumpy ride in the US and the UK
Developments that have been taking place in the United States and the United Kingdom can also be expected to have an impact internationally. The US tax-reform bill will, if it becomes law, result in a significantly altered international tax landscape, which will also be feeling the many significant changes we can expect as the countdown to Brexit continues.
Bron: Loyens & Loeff
Informatiesoort: Nieuws
Rubriek: Belastingrecht algemeen, Internationaal belastingrecht
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