E-News provides you with EU tax news that is current and relevant to your business.  KPMG's EU Tax Centre compiles a regular update of EU tax developments that can have both a domestic and a cross-border impact.  ECJ cases can have implications for your country.

AG opinion in the SCA Group Holding joined cases - Freedom of establishment – loss relief – balanced allocation of taxing rights - double use of losses - coherence

On February 27, 2014, Attorney-General Kokott (AG) of the Court of Justice of the European Union (CJEU) issued her opinion in the SCA Group Holding joined cases (C-39/13, C-40/13, and C-41/13). The Advocate General concluded that the Dutch rules are in breach of the freedom of establishment insofar as they deny tax consolidation between a Dutch parent company and a Dutch sub-subsidiary held through a foreign subsidiary, or between two Dutch sister subsidiaries and their foreign parent company. The CJEU now has to rule on the case. For further information, read our Euro Tax Flash and the February 2014 report (PDF 73 KB) prepared by the KPMG member firm in the Netherlands.

EU - European Parliament and Council reach agreement on Commission proposal to improve transparency

On February 26, 2014, the European Parliament and the Council reached agreement to amend the existing accounting legislation 2013/34/EU, which will make it mandatory for certain large companies to disclose non-financial and diversity information. It was agreed that any updates to country-by-country tax reporting would be based on a European Commission report, due for release in July 2018, which will take into account international developments on this issue. In order to become law, the Commission's proposal needs to be adopted jointly by the European Parliament and by the EU Member States in the Council (which votes by qualified majority). It is expected that the European Parliament will vote on this legislation in plenary session in April, after which the Council will formally adopt it.

OECD - Publication of the comments received on the Discussion Draft on transfer pricing documentation and country-by-country reporting

On March 3, 2014, the OECD published the comments received on its Discussion Draft on transfer pricing documentation and country-by-country reporting, which can be accessed through the following link to their site.

OECD - Revised timeline for BEPS discussion drafts, public consultations

On February 20, 2014, the OECD released a revised timeline for action relating to base erosion and profit shifting (BEPS) discussion drafts and public consultations. The first output from the BEPS project is expected in September 2014, with completion of the project due in 2015. The revised timetable provides the dates on which discussion drafts will be published and public consultations held in relation to the September 2014 actions.

The discussion drafts set for release and the dates on which they will be released are:

  • Tax treaty abuse – March 17, 2014
  • Tax challenges of the digital economy – March 24, 2014
  • Hybrid mismatch arrangements – April 4, 2014

Switzerland - Report on international financial and tax matters published

In February 2014, the Federal Department of Finance published the annual Report on international financial and tax matters 2014 (PDF 2.33 MB). Regarding international tax, the report notes Switzerland's activities in this field in respect of multilateral cooperation, such as the signing of the multilateral Convention on Mutual Administrative Assistance in Tax Matters, within the EU, e.g. the start of negotiations on revising the agreement with the EU on taxation of savings and in respect of bilateral relations, e.g. the tax agreements with Austria and the United Kingdom which took effect as of January 1, 2013.

United Kingdom – actions against tax evasion

A "corporate report" has been issued by the UK tax authorities (HMRC), which sets out how offshore tax evasion is addressed in the UK and internationally.

Read a February 2014 report (PDF 696 KB) prepared by the KPMG member firm in the UK: Weekly Tax Briefing (28 February 2014).

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The KPMG Guide to CCCTB

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The Guide discusses how, despite the political and technical obstacles, CCCTB is a serious proposal, and it deserves to be treated as such.

Financial Transaction Tax

The latest information on the EU’s FTT proposal and various country FTTs.