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OECD BEPS Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

Action 6 of the OECD BEPS Action Plans deals with the prevention of double tax treaty (hereinafter: treaty) abuse. OECD finds that one of the most pressing BEPS issues is treaty abuse and especially the so-called treaty shopping (which basically means the use of tax benefits deriving from residence related and other differences between treaties) and for this reason, a separate action plan was dedicated to this matter.

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EKAER number without reporting obligation – one uncertainty less!

In accordance with the regulation currently in force, it cannot be determined unambiguously regarding the fulfilment of the EKAER (Electronic Trade and Transport Control) reporting obligation whether any sanctions apply if an EKAER number is requested for a movement of goods involving public road transport, which would be exempted according to the regulation from the obligation of reporting in the EKAER system.

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