Michaela Merz

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EU – Corporate tax avoidance: Transparency rules adopted for tax

On 25 May 2018, the Council adopted rules aimed at boosting transparency to prevent aggressive cross-border tax planning.

The directive targets intermediaries such as tax advisors, accountants and lawyers that design and/or promote tax planning schemes. It will require them to report schemes that are potentially aggressive.

The information received will be automatically exchanged through a centralised database. Penalties will be imposed on intermediaries that do not comply.

“The new rules are a key part of our strategy to combat corporate tax avoidance “, said Vladislav Goranov, minister for finance of Bulgaria, which currently holds the Council presidency. “With greater transparency, risks will be detected at an earlier stage and measures taken to close down loopholes before revenue is lost.”

The directive was adopted at a meeting of the Economic and Financial Affairs Council, without discussion. Member States will have until 31 December 2018 to transpose it into national laws and regulations.

What does it mean 

All tax arrangements as from June 2018 will need to be identified however the information to the tax authority will have to be provided only as from 2020.

Find more details here:



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EU – Possible additional duties on products of US origin

The US has announced safeguard measures in the form of additional duties on imports of certain steel and aluminum products into the US. At the moment the implementation of these additional duties for products from the EU is postponed until June 1st 2018. As a counter measure, last week the EU published a commission implementing regulation: (EU) 2018/724. Continue reading

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Germany – The German Federal Fiscal Court doubts the constitutionality of additional payment interest

The German Federal Fiscal Court (Bundesfinanzhof – BFH) doubts the constitutionality of supplementary payment interest of 1.5% for interest periods from 2015, and has therefore granted a suspension of execution in a summary procedure. Continue reading

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EU Commission – Possible VAT implications of Transfer Pricing

I would like to share with you the paper with the opinion of the EU Commission VAT Expert Group issued on 18 April 2018 on possible VAT implications of Transfer Pricing.
The paper contains also interesting examples which could be of interest for you. Continue reading

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France – Audit trail documentation – Non established company VAT registered – new obligation

As you may know, the French tax law and doctrine requires that any taxpayers in France provide with a specific VAT audit trail documentation in case of tax audit.

From now, such requests were usually applied by the FTA to the French based companies. Continue reading

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South Korea – Internal control over financial reporting

I read shortly changes in South Korea about audit in financial reporting. I was fascinated about the increasing responsibilities and surprisingly penalties in case companies should not behave in line with the law. Whether or not we are getting step closer to full transparency and absolut correctness of reporting the future will show. Continue reading