CBR: the EU test case for ruling requests
Several EU Member States have decided to start a test case with regard to the ruling policy, in cross-border situations (CBR).
EU Member States have eventually gotten a deal regarding common procedures in tax rulings. It is a test case, officially started on 1 June 2013 and expected to continue until 30 September 2018, that aims to receive requests and questions from taxable persons and companies involved in cross-border transactions.
The EMS is an intergovernmental organisation created to provide financial assistance to Eurozone Members States in difficulty. It was introduced by the European Stability Mechanism Treaty signed on 2 February 2012. How does it work? How does it operate? What are ‘Dual limb CACs’?
CBR: the EU test case for ruling requests
Several EU Member States have decided to start a test case with regard to the ruling policy, in cross-border situations (CBR).
EU Member States have eventually gotten a deal regarding common procedures in tax rulings. It is a test case, officially started on 1 June 2013 and expected to continue until 30 September 2018, that aims to receive requests and questions from taxable persons and companies involved in cross-border transactions.
The EMS is an intergovernmental organisation created to provide financial assistance to Eurozone Members States in difficulty. It was introduced by the European Stability Mechanism Treaty signed on 2 February 2012. How does it work? How does it operate? What are ‘Dual limb CACs’?
De vzw Molenbeek Sport kreeg in 2017 59.720 euro van de EU in het kader van het pilootproject 'MONITORING AND COACHING, THROUGH SPORT ,OF YOUNGSTERS AT RISK OF RADICALISATION'.
Euro shorts 16.12.16 including Brexit: European Parliament briefing and Brexi...Cummings
Welcome to Euro Shorts, a short briefing on some of the week’s developments in the financial services industry in Europe.
If you would like to discuss any of the points we raise below, please contact me or one of our other lawyers.
BREXIT (Britain Exit) The Reasons & ImpactsSlide Gen
BREXIT_The Reasons & Impacts
Brexit is an abbreviation of "British exit". In 23 June 2016 Britain came out from European Union (EU) by the Vote of Britain’s people.
After Having 43 years of membership this great country makes this big decision. In 1973 United Kingdom got the membership in EU to expand the business among 28 members and share a common economical system.
EU VAT Alert: EU agrees to a generalised system of VAT reverse chargeAlex Baulf
Member States are currently under a severe threat from fraudsters who take advantage of the EU VAT system. The VAT gap – the difference between the amount of VAT that is forecast to be collectable by the Member States and the amount that is actually collected – runs to many billions of Euros.
For trade in certain goods, Member States are currently entitled to designate the purchaser as the entity obliged to pay the VAT due on the transaction. The system is known as the reverse charge mechanism and it is now used for most B2B transactions for intra EU supplies of services.
Following a recent ECOFIN meeting, we understand that the Czech Finance Minister - Andrej Babis is claiming that the EU Commission has agreed to an extension to the reverse charge mechanism to cover all supplies of goods. The Commission has, apparently, agreed to introduce legislation to implement a generalised reverse charge system by as soon as the end of 2016. This would constitute a change of heart by the Commission which has previously opposed such a move.
However, we understand that Mr Babis threatened to veto other measures aimed at combating corporate tax avoidance. The quid pro quo for his co-operation was the Commissions agreement to the introduction of the generalised reverse charge system.
Comment – The Commission is anxious to reduce the level of VAT fraud with the EU. Indeed, it states as much in its recent 'Action Plan for VAT'. Businesses involved in selling goods will wish to keep an eye on these developments as their VAT reporting and accounting systems will need to be re-configured.
Euro shorts 09.09.16 including Brexit update: Theresa May meeting with Donald...Cummings
Welcome to Euro Shorts, a short briefing on some of the week’s developments in the financial services industry in Europe.
If you would like to discuss any of the points we raise below, please contact me or one of our other lawyers.
The United Kingdom’ s Diverted Profits Tax and Tax Treaties: An EvaluationRamon Tomazela
This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
De vzw Molenbeek Sport kreeg in 2017 59.720 euro van de EU in het kader van het pilootproject 'MONITORING AND COACHING, THROUGH SPORT ,OF YOUNGSTERS AT RISK OF RADICALISATION'.
Euro shorts 16.12.16 including Brexit: European Parliament briefing and Brexi...Cummings
Welcome to Euro Shorts, a short briefing on some of the week’s developments in the financial services industry in Europe.
If you would like to discuss any of the points we raise below, please contact me or one of our other lawyers.
BREXIT (Britain Exit) The Reasons & ImpactsSlide Gen
BREXIT_The Reasons & Impacts
Brexit is an abbreviation of "British exit". In 23 June 2016 Britain came out from European Union (EU) by the Vote of Britain’s people.
After Having 43 years of membership this great country makes this big decision. In 1973 United Kingdom got the membership in EU to expand the business among 28 members and share a common economical system.
EU VAT Alert: EU agrees to a generalised system of VAT reverse chargeAlex Baulf
Member States are currently under a severe threat from fraudsters who take advantage of the EU VAT system. The VAT gap – the difference between the amount of VAT that is forecast to be collectable by the Member States and the amount that is actually collected – runs to many billions of Euros.
For trade in certain goods, Member States are currently entitled to designate the purchaser as the entity obliged to pay the VAT due on the transaction. The system is known as the reverse charge mechanism and it is now used for most B2B transactions for intra EU supplies of services.
Following a recent ECOFIN meeting, we understand that the Czech Finance Minister - Andrej Babis is claiming that the EU Commission has agreed to an extension to the reverse charge mechanism to cover all supplies of goods. The Commission has, apparently, agreed to introduce legislation to implement a generalised reverse charge system by as soon as the end of 2016. This would constitute a change of heart by the Commission which has previously opposed such a move.
However, we understand that Mr Babis threatened to veto other measures aimed at combating corporate tax avoidance. The quid pro quo for his co-operation was the Commissions agreement to the introduction of the generalised reverse charge system.
Comment – The Commission is anxious to reduce the level of VAT fraud with the EU. Indeed, it states as much in its recent 'Action Plan for VAT'. Businesses involved in selling goods will wish to keep an eye on these developments as their VAT reporting and accounting systems will need to be re-configured.
Euro shorts 09.09.16 including Brexit update: Theresa May meeting with Donald...Cummings
Welcome to Euro Shorts, a short briefing on some of the week’s developments in the financial services industry in Europe.
If you would like to discuss any of the points we raise below, please contact me or one of our other lawyers.
The United Kingdom’ s Diverted Profits Tax and Tax Treaties: An EvaluationRamon Tomazela
This article examines the diverted profits tax
(DPT) introduced by the United Kingdom to
counter aggressive tax planning adopted by
many multinational enterprises so as to transfer
profits from its jurisdiction, and the main
controversies surrounding the compatibility of
the DPT with tax treaties.
On your mark EU Financial Transaction Tax for asset managersKNOWitALL
TO GET READY FOR THE EU FINANCIAL TRANSACTION TAX FINANCIAL INSTITUTIONS ARE IN A RACE AGAINST TIME AND POLITICS!
The article reviews the progress of legislative developments regarding the Financial Transactions Tax proposed by 11 member states of the EU. Drawing from the industry’s experience of implementing similar transaction taxes it analyses impact from the perspective of the operational challenges posed and makes a case for considering these wider implications in time to ensure regulatory compliance.
A look at intra-group loans and safe harbour rules in CyprusChristos Theophilou
Christos Theophilou and Demis Ioannou of Taxatelier present a case study of how the Cypriot tax authorities use safe harbour rules in determining arm’s-length interest rates. The article appears in International Tax Review, published by Euromoney PLC.
Rapport PwC sur la taxe sur les transactions financières (2013)PwC France
http://pwc.to/1emGNhP
L'objectif de ce rapport est de revoir et de distiller indépendamment les points principaux des textes proposés par la Commission Européenne pour harmoniser les Financial Transaction Tax dans l'Union Européenne.
The significant tax regulations came into force as of January 2017 and introduced requirement to demonstrate that terms of cooperation and settlements between related parties were determined in line with the arm’s length principle. Moreover, during 2017 and 2018 some importance long-anticipated decree were published. Those documents implement for example:
UN Model Tax Convention Vs OECD Model Tax Convention Significance of Distinctiontaxguru4
As the world moves increasingly towards economic integration and globalization there is a lot of cross border trade, investment and business which will only increase as more and more developing and least developed countries open up their borders for more business with the international community....
La Comisión europea informa sobre el progreso social en la UE.ManfredNolte
Bruselas confirma que el progreso social varía notablemente entre las regiones de la Unión Europea, y que los países nórdicos tienen un desempeño consistentemente mejor que el resto de los Estados miembros.
EL MERCADO LABORAL EN EL SEMESTRE EUROPEO. COMPARATIVA.ManfredNolte
Hoy repasaremos a uña de caballo otro reciente documento de la Comisión (SWD-2024) que lleva por título ‘Análisis de países sobre la convergencia social en línea con las características del Marco de Convergencia Social (SCF)’.
PIB,OKUN Y PARO ESTRUCTURAL: RELACIONES DIRECTAS E INVERSASManfredNolte
Me refiero a las ‘Previsiones económicas de primavera’ de la Comisión europea, que se han constituido la semana pasada en panegírico de nuestras bondades y que, como es natural, han sido aprovechadas por el Gobierno para el autobombo.
LOS MIMBRES HACEN EL CESTO: AGEING REPORT.ManfredNolte
El Informe sobre el envejecimiento concentra un ejercicio único en el sentido de que proporciona proyecciones para los Estados miembros de la UE y Noruega hasta 2070 basadas en datos supuestos y metodologías comunes. El informe suministra un amplio conjunto de datos comparables e internos para 28 países. Dan una idea del momento en que se produce el envejecimiento de la población, sus implicaciones económicas y los desafíos presupuestarios asociados.
Empresarios privados y públicos: ¿adversarios o aliados?ManfredNolte
La reciente notificación de la Sociedad Estatal de Participaciones Industriales (SEPI), acerca de la toma de un porcentaje relevante en el Capital de Telefónica, ha reabierto la recurrente polémica sobre la figura del Estado como Empresario público, su conveniencia, su oportunidad y su eficiencia
CARE ECONOMY: LA VIEJA Y NUEVA ECONOMIA DE LOS CUIDADOS.ManfredNolte
La economía del cuidado entiende del reconocimiento y valoración de todas las actividades que contribuyen a la atención de las personas, incluido el trabajo no remunerado realizado en los hogares, así como el trabajo remunerado que involucra el cuidado de niños, personas mayores, personas con discapacidades y aquellas que necesitan cualquier tipo de atención especial.
DEUDA PUBLICA Y CONVENIENCIA FISCAL: LLAMADOS AL ACUERDO.ManfredNolte
En su conjunto y en rasgos generales, el progreso de la economía, es decir el de su PIB, depende de dos fuentes básicas de alimentación: el aumento de sus factores productivos y el incremento de su productividad.
DESIGUALDAD PERMANENTE: EL ESTANCAMIENTO DE LA DISTRIBUCIÓN DE LA RIQUEZA.ManfredNolte
La teoría del ‘derrame’ postula atenuar la presión sobre las rentas de los grupos sociales con mayor propensión al ahorro, esto es, los sectores de mayores ingresos, sobre la base de su capacidad de ahorrar e invertir,
COYUNTURA ECONOMICA Y SUS SOMBRAS: INFORME TRIMESTRAL DEL BANCO DE ESPAÑA.ManfredNolte
h
Hay que recordar, que los fotos puntuales, aun cuando salgan bien, no pueden encubrir las carencias, las flaquezas de fondo, que en distintos flancos acechan a nuestra economía.
DESVELANDO LA REALIDAD SOCIAL: ENCUESTA DE CONDICIONES DE VIDA EN ESPAÑA.ManfredNolte
Junto a la de la tolerancia hacia los Paraísos fiscales, último vertedero de la evasión fiscal y del crimen organizado, la pobreza se constituye probablemente en la mayor de las grandes vergüenzas que se confinan en los búnkeres de la economía de mercado.
¿FIN DEL CRIPTOINVIERNO?: ASI HABLAN LOS MAXIMOS.ManfredNolte
Hay creencias firmes, impertérritas, capaces de sobrevivir a cualquier duda o adversidad, ajenas a las opiniones contrarias o simplemente nuevas, ciegas y sordas a cualquier idea o consejo que las desvíe de su camino.
CONOCIMIENTO INTERIOR BRUTO, la obsolescencia del PIB.ManfredNolte
El PIB no es un indicador exhaustivo del progreso económico y tampoco de bienestar social; Además el índice está ofreciendo registros descorazonadores.
LA AGROSFERA, DE NUEVO LA REBELIÓN DEL CAMPO.ManfredNolte
La reciente explosión de los agricultores -una más de una larga cadena histórica- es un suceso emocional y espontaneo y como tal no responde a un enunciado claro de reivindicaciones como podrían constar en un documento unificado de propuestas del sector.
TAMAÑO DEL ESTADO Y BIENESTAR EN LA OCDE.ManfredNolte
Hay un valor entendido, un tópico que circula en amplias capas de la opinión económica, incluso de la habitualmente informada, acerca de la existencia de un antagonismo de raíz entre los conceptos de libre mercado e intervención gubernamental.
MAS ALLA DE LA INCERTIDUMBRE:DESAFIOS DE LA ECONOMIA ESPAÑOLA.ManfredNolte
Un reciente informe de la OCDE (Economic Policy Papers, No. 33), avanza que la economía española retrocederá diez posiciones en la clasificación mundial de países por PIB per cápita, pasando desde la posición 23 en la actualidad a la posición 33 en 2060 .
DAVOS: EL PESO Y EL CONSEJO DE UN PODER SOCIALIZADOR.ManfredNolte
Al pie de la montaña mágica de Tomas Mann, enero en la elite es ya sinónimo de esta especial convención, entendiendo por especial no solo el ‘espíritu de Davos’, sino también la naturaleza de sus invitados. Durante cinco días la apacible estación de esquí invernal se transforma en la más selecta y cosmopolita feria del planeta.
Encryption in Microsoft 365 - ExpertsLive Netherlands 2024Albert Hoitingh
In this session I delve into the encryption technology used in Microsoft 365 and Microsoft Purview. Including the concepts of Customer Key and Double Key Encryption.
Accelerate your Kubernetes clusters with Varnish CachingThijs Feryn
A presentation about the usage and availability of Varnish on Kubernetes. This talk explores the capabilities of Varnish caching and shows how to use the Varnish Helm chart to deploy it to Kubernetes.
This presentation was delivered at K8SUG Singapore. See https://feryn.eu/presentations/accelerate-your-kubernetes-clusters-with-varnish-caching-k8sug-singapore-28-2024 for more details.
Welocme to ViralQR, your best QR code generator.ViralQR
Welcome to ViralQR, your best QR code generator available on the market!
At ViralQR, we design static and dynamic QR codes. Our mission is to make business operations easier and customer engagement more powerful through the use of QR technology. Be it a small-scale business or a huge enterprise, our easy-to-use platform provides multiple choices that can be tailored according to your company's branding and marketing strategies.
Our Vision
We are here to make the process of creating QR codes easy and smooth, thus enhancing customer interaction and making business more fluid. We very strongly believe in the ability of QR codes to change the world for businesses in their interaction with customers and are set on making that technology accessible and usable far and wide.
Our Achievements
Ever since its inception, we have successfully served many clients by offering QR codes in their marketing, service delivery, and collection of feedback across various industries. Our platform has been recognized for its ease of use and amazing features, which helped a business to make QR codes.
Our Services
At ViralQR, here is a comprehensive suite of services that caters to your very needs:
Static QR Codes: Create free static QR codes. These QR codes are able to store significant information such as URLs, vCards, plain text, emails and SMS, Wi-Fi credentials, and Bitcoin addresses.
Dynamic QR codes: These also have all the advanced features but are subscription-based. They can directly link to PDF files, images, micro-landing pages, social accounts, review forms, business pages, and applications. In addition, they can be branded with CTAs, frames, patterns, colors, and logos to enhance your branding.
Pricing and Packages
Additionally, there is a 14-day free offer to ViralQR, which is an exceptional opportunity for new users to take a feel of this platform. One can easily subscribe from there and experience the full dynamic of using QR codes. The subscription plans are not only meant for business; they are priced very flexibly so that literally every business could afford to benefit from our service.
Why choose us?
ViralQR will provide services for marketing, advertising, catering, retail, and the like. The QR codes can be posted on fliers, packaging, merchandise, and banners, as well as to substitute for cash and cards in a restaurant or coffee shop. With QR codes integrated into your business, improve customer engagement and streamline operations.
Comprehensive Analytics
Subscribers of ViralQR receive detailed analytics and tracking tools in light of having a view of the core values of QR code performance. Our analytics dashboard shows aggregate views and unique views, as well as detailed information about each impression, including time, device, browser, and estimated location by city and country.
So, thank you for choosing ViralQR; we have an offer of nothing but the best in terms of QR code services to meet business diversity!
Key Trends Shaping the Future of Infrastructure.pdfCheryl Hung
Keynote at DIGIT West Expo, Glasgow on 29 May 2024.
Cheryl Hung, ochery.com
Sr Director, Infrastructure Ecosystem, Arm.
The key trends across hardware, cloud and open-source; exploring how these areas are likely to mature and develop over the short and long-term, and then considering how organisations can position themselves to adapt and thrive.
Observability Concepts EVERY Developer Should Know -- DeveloperWeek Europe.pdfPaige Cruz
Monitoring and observability aren’t traditionally found in software curriculums and many of us cobble this knowledge together from whatever vendor or ecosystem we were first introduced to and whatever is a part of your current company’s observability stack.
While the dev and ops silo continues to crumble….many organizations still relegate monitoring & observability as the purview of ops, infra and SRE teams. This is a mistake - achieving a highly observable system requires collaboration up and down the stack.
I, a former op, would like to extend an invitation to all application developers to join the observability party will share these foundational concepts to build on:
Le nuove frontiere dell'AI nell'RPA con UiPath Autopilot™UiPathCommunity
In questo evento online gratuito, organizzato dalla Community Italiana di UiPath, potrai esplorare le nuove funzionalità di Autopilot, il tool che integra l'Intelligenza Artificiale nei processi di sviluppo e utilizzo delle Automazioni.
📕 Vedremo insieme alcuni esempi dell'utilizzo di Autopilot in diversi tool della Suite UiPath:
Autopilot per Studio Web
Autopilot per Studio
Autopilot per Apps
Clipboard AI
GenAI applicata alla Document Understanding
👨🏫👨💻 Speakers:
Stefano Negro, UiPath MVPx3, RPA Tech Lead @ BSP Consultant
Flavio Martinelli, UiPath MVP 2023, Technical Account Manager @UiPath
Andrei Tasca, RPA Solutions Team Lead @NTT Data
GDG Cloud Southlake #33: Boule & Rebala: Effective AppSec in SDLC using Deplo...James Anderson
Effective Application Security in Software Delivery lifecycle using Deployment Firewall and DBOM
The modern software delivery process (or the CI/CD process) includes many tools, distributed teams, open-source code, and cloud platforms. Constant focus on speed to release software to market, along with the traditional slow and manual security checks has caused gaps in continuous security as an important piece in the software supply chain. Today organizations feel more susceptible to external and internal cyber threats due to the vast attack surface in their applications supply chain and the lack of end-to-end governance and risk management.
The software team must secure its software delivery process to avoid vulnerability and security breaches. This needs to be achieved with existing tool chains and without extensive rework of the delivery processes. This talk will present strategies and techniques for providing visibility into the true risk of the existing vulnerabilities, preventing the introduction of security issues in the software, resolving vulnerabilities in production environments quickly, and capturing the deployment bill of materials (DBOM).
Speakers:
Bob Boule
Robert Boule is a technology enthusiast with PASSION for technology and making things work along with a knack for helping others understand how things work. He comes with around 20 years of solution engineering experience in application security, software continuous delivery, and SaaS platforms. He is known for his dynamic presentations in CI/CD and application security integrated in software delivery lifecycle.
Gopinath Rebala
Gopinath Rebala is the CTO of OpsMx, where he has overall responsibility for the machine learning and data processing architectures for Secure Software Delivery. Gopi also has a strong connection with our customers, leading design and architecture for strategic implementations. Gopi is a frequent speaker and well-known leader in continuous delivery and integrating security into software delivery.
DevOps and Testing slides at DASA ConnectKari Kakkonen
My and Rik Marselis slides at 30.5.2024 DASA Connect conference. We discuss about what is testing, then what is agile testing and finally what is Testing in DevOps. Finally we had lovely workshop with the participants trying to find out different ways to think about quality and testing in different parts of the DevOps infinity loop.
Essentials of Automations: Optimizing FME Workflows with ParametersSafe Software
Are you looking to streamline your workflows and boost your projects’ efficiency? Do you find yourself searching for ways to add flexibility and control over your FME workflows? If so, you’re in the right place.
Join us for an insightful dive into the world of FME parameters, a critical element in optimizing workflow efficiency. This webinar marks the beginning of our three-part “Essentials of Automation” series. This first webinar is designed to equip you with the knowledge and skills to utilize parameters effectively: enhancing the flexibility, maintainability, and user control of your FME projects.
Here’s what you’ll gain:
- Essentials of FME Parameters: Understand the pivotal role of parameters, including Reader/Writer, Transformer, User, and FME Flow categories. Discover how they are the key to unlocking automation and optimization within your workflows.
- Practical Applications in FME Form: Delve into key user parameter types including choice, connections, and file URLs. Allow users to control how a workflow runs, making your workflows more reusable. Learn to import values and deliver the best user experience for your workflows while enhancing accuracy.
- Optimization Strategies in FME Flow: Explore the creation and strategic deployment of parameters in FME Flow, including the use of deployment and geometry parameters, to maximize workflow efficiency.
- Pro Tips for Success: Gain insights on parameterizing connections and leveraging new features like Conditional Visibility for clarity and simplicity.
We’ll wrap up with a glimpse into future webinars, followed by a Q&A session to address your specific questions surrounding this topic.
Don’t miss this opportunity to elevate your FME expertise and drive your projects to new heights of efficiency.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...DanBrown980551
Do you want to learn how to model and simulate an electrical network from scratch in under an hour?
Then welcome to this PowSyBl workshop, hosted by Rte, the French Transmission System Operator (TSO)!
During the webinar, you will discover the PowSyBl ecosystem as well as handle and study an electrical network through an interactive Python notebook.
PowSyBl is an open source project hosted by LF Energy, which offers a comprehensive set of features for electrical grid modelling and simulation. Among other advanced features, PowSyBl provides:
- A fully editable and extendable library for grid component modelling;
- Visualization tools to display your network;
- Grid simulation tools, such as power flows, security analyses (with or without remedial actions) and sensitivity analyses;
The framework is mostly written in Java, with a Python binding so that Python developers can access PowSyBl functionalities as well.
What you will learn during the webinar:
- For beginners: discover PowSyBl's functionalities through a quick general presentation and the notebook, without needing any expert coding skills;
- For advanced developers: master the skills to efficiently apply PowSyBl functionalities to your real-world scenarios.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...
Documento ue preguntas ttf
1. 1
ROOM DOCUMENT # 4
Working Party on Tax Questions –
Indirect Taxation (Financial Transaction Tax)
16 April 2013
ORIGIN: BE, DE, EE, EL, ES, FR, IT, AT, PT, SI, SK
Implementing enhanced cooperation in the area of Financial Transaction Tax
Questions to the Commission from the working level
This non-paper summarizes questions of the participating member states on the working level to the
Commission concerning the proposal for implementing enhanced cooperation in the area of
financial transaction tax. This non-paper is provided purely for information purposes.
The participating Member States strongly welcome the Commission’s proposal for enhanced
cooperation. It is necessary to harmonize rules for the taxation of financial transactions. In order to
quickly make further progress with our work the participating member states ask for clarifications
in the following areas:
Collection of the tax
• Acts implementing collection and declaration of the tax
Article 11, par. 1 of the Proposal for a Council Directive implementing enhanced cooperation in the
area of financial transaction tax (the Proposal) states that “the participating Member States shall
lay down registration, accounting reporting obligations and other obligations intended to ensure
that FTT due is effectively paid to the tax authorities”. Nevertheless, common general principles
governing the collection and the declaration of the tax already included in the text of the Directive.
could help facilitating: (i) the cross-border exchange of information amongst different MS or
between MS and other third countries; (ii) the market operators and persons paying/ collecting the
tax, by having a common system of collection and declaration in the different countries where
they might have to pay/declare; (iii) the reduction of costs of implementation, as a result of the
above; (iv) the implementation for both the market and the tax authorities, by having common
rules and forms already defined.
Given the above, the 11 MS are also aware that the specific details regarding (for example) the
methods of the collection and the tax return forms cannot be contained in the Directive.
As a consequence, the 11 MS would like to ask the Commission which acts could allow to further
implement more in detail the general and common principles they would like to include in Article
11 of the Directive.
Would it be feasible to implement in more detail the general and common principles of collection
and declaration of the tax in the Directive?
More specifically, which kind of legal acts and which procedure could allow them to work together
on the definition of the details, forms, etc for a common collection and declaration system?
Last, how would the use of “implementing acts” work in case of the enhanced cooperation? Which
MS would participate to the committee provided for by Article 5 of the Regulation 182/2011?
2. 2
• Cross-border exchange of information and recovery of the tax
What are the Commission’s plans to ensure the successful implementation of the FTT as far as non-
EU member countries are concerned? In particular, what type of contacts/negotiations does the
Commission believe should be established with non-EU governments/financial institutions?
For example, with regard to the exchange of information, the OECD Model has amended in year
2000 Art.26 by including also other taxes not covered by the other articles of the treaty (“The
competent authorities of the Contracting States shall exchange such information as is foreseeably
relevant for carrying out the provisions of this Convention or to the administration or enforcement
of the domestic laws concerning taxes of every kind”). Only treaties signed or amended after that
date may contain the provision of exchange of information on all the taxes, but from experience of
some MS very few treaties include it. Similar considerations can be made on Article 27.
With respect to the OECD-Council of Europe Multilateral Convention on Mutual Administrative
Assistance in Tax Matters, if the FTT should be considered as included in Article 2, paragraph 1.b.iii
G (“any other taxes”), then very few countries would allow the exchange of information on FTT, and
still less would grant the assistance in recovery of tax credits.
As a result, what is the Commission’s view on the potential application of current double taxation
treaties or other Conventions to ensure effective exchange of information/cooperation in the
collection of the FTT?
Liable person
The definition of “Financial institution” should not lead to some distortionary effects or to some
circumvention of the tax by shifting, to transactions where a financial institution is not involved.
In case of listed instruments, there may be situations in which no “financial institution” as defined
in Article 2 of the Directive is involved in the transaction.
In case of non-listed instruments, in many situations no “financial institution” is involved (but
mainly Notary Public, or direct transaction between the parties, etc).
How would the FTT apply in these cases?
Last, when shares are exchanged between two different entities with no intermediaries, sending
the order to their depositary entity, would this transaction be taxed?
Bonds
• Government bonds
The impact assessment accompanying the document Proposal (SWD(2013)28 Final) it is not fully
clear on how the taxation on government bonds would interact with the cost of national debt and
whether at the overall level of the 11 MS the negative effect of the increase of the cost of national
debts could be counterbalanced by the revenues of the FTT.
3. 3
In particular, it is not clear:
(i) if the redistribution effect amongst the 11 MS has been considered or not by the
Commission, and if yes, which are the related figures (the present scope of the Commission’s
proposal in terms of “territoriality” would not allow each MS to collect the whole EU FTT paid
on the bonds issued by the same MS. As a result, the increase of cost of government debt
which one MS would bear due to the application of the EU FTT would not necessarily be
compensated by the collection of the tax on the same instruments. In the “impact
assessment” accompanying the Proposal the Commission affirms that “for each euro
potentially to be spent on higher interest rates governments would receive more than three
euro in return in form of higher FTT revenue (gross revenue)”.
Could the Commission detail such analysis? Could the Commission explain in particular the
redistributive effect of revenues amongst participating MS deriving from the specific
“territorial” principle contained in the Proposal?
(i) how the figures indicated in the impact assessment are calculated; in particular, it is not clear
how the Commission estimated the 2bn euro related to the mitigating effects, as well as more
clarifications would be requested on the calculation of the 0.07% increase of the public
budgets and on the revenues from bonds.
Can the Commission give evidence of such estimates?
Regarding the low maturity of the repo operations on sovereign bonds market (more than two
thirds of repo operations on sovereign bonds have a maturity lower than three days), the tax will
induce an additional cost that is not sustainable for the market participants, ie companies and
Member States which need to manage properly their cash in a secure environment. The extinction
of the market will negatively affect the sovereign bonds market and by consequence will rise the
government funding costs. Repo operations are very useful for managing the treasury liquidity and
the disappearance of this market combined by the lack of viable alternatives will induce serious
problems about risk management. The problem also holds for banks in managing their marginal
liquidity and might cause both higher financial costs on the real economy and financial stability
issues.
Is there an assessment about the effect of the tax on the repo market and therefore on the funding
cost of the central government and the real economy ?
Furthermore, what impact will the tax have on the costs of government funding taking into
consideration the costs of transactions on the repo and cash markets and the efforts to reduce
public debt ?
• Tax formula
Could you state the effects of a tax formula which takes into account the duration of the bond on
which the transaction takes place or is it preferable to set up lower minimum tax rates in general?
The 0.1% uniform tax rate proposed by the Commission might create an inappropriate burden on
short term bonds, repo operations etc, compared to long term bonds. A possible imbalance would
have implications on the cost of the debt, including sovereign debt, on financial institutions’
refinancing operations, as well as on the part of the asset management industry that is focused on
short term maturities
4. 4
• Non-government bonds
With regards to other bonds, business have expressed worries that the same effect described
above for government bonds would replicate on the corporate issuers, with negative effects on the
financing capability of companies. Considering, on the one hand, the difficulties in receiving funding
from the banking sector in the present environment, and on the other hand the fact that
exceptions on the FTT should be limited/reasonable, MS would like more information on the
expected revenues from taxation on non-governments bonds.
Considering all the above, MS would like to receive from the Commission more evidence
and information also with regards to the estimated figures related to non-government
bonds. Where does COM see the delamination between private and public sector bonds/debt,
namely, how are bonds treated that are issued by private companies that are 100% public
owned or 100% public guaranteed and how are CoCo bonds treated - as private or as public,
regardless of the ownership of the bank?
• Primary exemptions on bonds
Are the acquisitions of UCITS share exempted through the primary market exemption, as defined in Article
3.4.a?
Are bonds of legal entities guaranteed by Member States included? More generally are all bonds of public
entities included (such as local authorities)
Definitions and clarification on the scope of taxation:
The 11 MS consider that some definitions should be clarified by the Commission.
• Purchase and sale
Article 2, par. 1. (2) (a) mentions “the purchase and sale of a financial instrument before netting or
settlement” .
A common definition of “purchase and sale” is essential in order to have: (i) certainty in the legal
basis for both taxpayers and tax administrations; (ii) uniformity in the application of the tax among
participating MS. Considering that from a legal perspective the different MS may have different
interpretation of a “sale” or of a “purchase”, it is considered it as essential to agree on a common
definition.
What is the meaning of “purchase” and “sale” based on the Commission’s Proposal? Would it be
feasible in the view of the Commission to further define these terms or to come up with alternative
terms that are commonly defined within the MS?
5. 5
• Netting and settlement
The reference to the Article 2, lett. k, of the Directive 98/26/EC of the European Parliament and of
the Council for the meaning of netting does not seem sufficient to clarify it. Indeed, the Directive
affirms: “netting shall mean the conversion into one net claim or one net obligation of claims and
obligations resulting from transfer orders which a participant or participants either issue to, or
receive from, one or more other participants with the result that only a net claim can be demanded
or a net obligation be owed”. The reference to this Article does not clarify if the Commission wants
to refer to the netting by single instrument, per day, per financial institution, etc..
The 11 MS ask for clarifications on this. As mentioned above, they consider that also the meaning
of settlement should be more detailed.
• Cancellation and rectification
Article 5 of the Proposal states that “subsequent cancellation or rectification of a financial transaction
shall have no effect on chargeability, except for cases of errors”.
The 11 MS would like to have clarification on the meaning of “cancellation or rectification”.
• Pension funds (Art.2, par.1, nr 8, lett.f)
The 11 MS would like to have clarification on the definition of pension funds. In particular, are both
Pillar II and Pillar III included? In addition, reference is also made to “investment managers of such
funds”: are all pension funds management companies included?
• definition of „udertaking...“ (Art. 2, par.1, nr 8, lett. j, point ii)
Clarity is needed in the definition of this activity.
• definition of „udertaking...“ (Art. 2, par.1, nr 8, lett. j, point iv) and v)
This part of definition seems to be according to our reading not consistent with Art. 3, par.4, lett. a) where these primary
market transactions are excluded from the scope
High Frequency Trading:
The 11 MS would like to ask the Commission which would be the impact of their Proposal on High
Frequency traders.
What would be the impact of the Proposal on High Frequency traders in the context of taxing intraday
transactions? Are modifications and cancellations taxed? Are orders sent, even if cancelled or modified,
taxed ?
6. 6
Joint and several liability
The 11 MS would like some more clarifications and examples on par.3 of Article 10 of the Proposal, stating
that “ where the tax due has not been paid within the time limit set out in Article 11(5), each party to a
transaction, including persons other than financial institutions shall be jointly and severally liable for the
payment of the tax due by a financial institution on account of that transaction”.
In practice, how will the provision of joint liability work? How will the “customer” or other entity in the
chain know if the financial institution has paid or not a tax for which the financial institution is liable? Can
the Commission make some examples on how it could work? (Is it possible that very often parties do not
know which are all the financial institutions involved in the chain of the transaction since most of financial
transactions are anonymized and the parties do not know each other’s on organized markets before the
execution of the transaction)?.
Further clarification on the Commission’s impact assessment
According to the commission, the impact on traded volumes (-15% for securities) is an "ex-ante" working
hypothesis.
Considering the importance of this hypothesis on impact assessment both in terms of market reactions and
tax revenues, can the Commission elaborate on how it estimated such impact, especially between the
different securities depending on the issuer (sovereign, corporate, etc.), maturity (short or long), and
current liquidity?
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