Make sure you read the last paragraph!
Eric Miller - CPA, CGMA, CAMS’ Post
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As expected: the The White House announced that i) the 'Global Tax Deal' has no effect in relation to the US and ii) that the US will institute defensive measures against countries imposing a UTPR. Link: https://lnkd.in/eVgyFrZJ. 🇪🇺 Wonder how the EU and the Member States look at this from a strategic perspective. 🇳🇱 When asked by members of Dutch parliament (Wendy van Eijk - VVD - Tweede Kamer der Staten-Generaal & Paulien Geerdink - VVD - Eerste Kamer der Staten-Generaal), the answers suggested the Dutch Ministry of Finance (Ministerie van Financiën) has adopted a 'wait-and-see' approach.
We have sent many messages on Pillar One and Pillar Two. Therefor, this one cannot be skipped. https://lnkd.in/ec6yUfuw
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State Aid Ireland case Final verdict The EU Court of Justice confirms the decision from 2016 by the European Commission: Ireland granted a US MNE unlawful aid which Ireland now has to recover. And this judgement is final. As we all know, the EU Commission investigated several of these tax rulings and aggressive tax planning measures under State aid rules in the Belgian Excess Profit and three other cases. There were more. These are just a few of them. Today, the Court of Justice confirmed the decision in the Ireland case. In its decision in 2016, the Commission concluded that two Irish tax rulings constituted illegal State aid. They had artificially lowered taxes paid by a US MNE in Ireland since 1991. The Commission considered this to be a misapplication of Irish tax rules and ordered Ireland to recover up to 13 billion euros from this US MNE. These tax rulings attributed the bulk of taxable profits - of two Irish subsidiaries - to stateless "head offices". These head offices existed only on paper. No tables, no chairs, no activities. The profits were thus assumed not to be taxed anywhere. As an example, in 2011, one of the Irish subsidiaries recorded profits of approximately 16 billion euros. Of these, thanks to the tax rulings, only around 50 million euros were taxable in Ireland. So, this subsidiary paid less than 10 million euros of taxes in Ireland in 2011 - an effective tax rate of about 0.05% of these overall annual profits. More concretely, today the EU Court of Justice confirmed the Commission's approach that the intellectual property licences held by the Irish subsidiaries and related profits should have been allocated to the Irish branches. And that the US MNE should have paid taxes worth 13 billion euros on all related profits in Ireland. This means that the recovered taxes, which have been in an escrow account for quite some years in Ireland during the ongoing court proceedings, now must be released to the Irish State. Today, this Irish ruling case could no longer occur. Ireland changed its corporate tax residence rules to prevent Irish incorporated companies from being stateless for tax purposes. Finally, in the Netherlands, tax ruling policy changed: Since 2019, the Netherlands adopted legislation to counter the use of shell companies to avoid or evade taxes. A company is now required to have a meaningful economic presence in the Netherlands to obtain a tax ruling (and meet several other conditons).
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Thinking about tax planning for your 2024 tax return? Let's consider how AI may impact this in the future. https://lnkd.in/ewyhYu-M=linkedin/@taxgptai/ai-brings-personalized-precision-to-modern-tax-planning-3a0e5e2aec5e
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As the year ends, businesses can reduce tax liability, improve cash flow, and stay compliant with smart year-end tax planning. Don't miss these key tips to maximize savings! 💼💰 #TaxPlanning #BusinessTips #YearEndStrategy https://lnkd.in/ewyhYu-M=linkedin/@ashahzain059/year-end-tax-planning-tips-for-businesses-752865c055b4
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Thinking about tax planning for your 2024 tax return? Let's consider how AI may impact this in the future. https://lnkd.in/ejmkMc3J=linkedin/@taxgptai/ai-brings-personalized-precision-to-modern-tax-planning-3a0e5e2aec5e
