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European developments to watch for in 2015 2015 sees the European Commission under the leadership of a new President, Jean-Claude Juncker, and a new Commissioner for Taxation and Economic Affairs, Pierre Moscovici. Steve Bill, OBE Tax Policy and Controversy, Luxembourg Commissioner Moscovici would be more interested in the traditional focus on tax harmonization, while President Juncker, I believe, is more interested in pursuing the BEPS-type work. This is now being translated into a compromise in the Commission’s workplan for 2015. 9 the workplan, and it’s interesting that two out of the 23 key initiatives for the promised proposal for the disclosure of tax rulings between tax administrations. In theory, there is nothing wrong with tax rulings; most Member States give and indeed there are many tax incentives that are only available following an advance ruling. What the Commission is now looking into is whether the basis on which some of these rulings have been given constitutes State Aid. 9 rulings-practice-inquiry-to-all-Member-Statesand-announces-intention-for-new-Action-Plan-tocombat-tax-fraud-and-evasion 18 | The outlook for global tax policy in 2015
This is probably going to turn out to be a very small number as advance rulings are a normal and natural part of tax administration to give certainty to both tax administrators and companies. This is part of the drive for tax transparency, and we expect to see proposals issued very early in 2015. I understand that the Commission is evaluating whether its proposal for a simple extension of the could be extended to cover some of the were asking for. The question is whether market legal basis. Combating tax evasion and tax fraud The second tax element of the workplan is the action plan on efforts to combat tax evasion and tax fraud. 10 Reading where they are generated. This will bring the discussion to the core of the BEPS Project. Interestingly, the EU has sought to implement many of the debates taking place under the BEPS project. The exchange of information (EoI) had already been well developed in the EU has the most advanced model of EoI which is itself now forms a model for the Some commentators have questioned whether, with all the work going on (on has become largely irrelevant in this space. But I would argue that in fact the opposite is true — the EU has become the motor now for a lot of the work that is being done in the BEPS project. The European Union, the Commission and the Presidencies are working closely with the of the historic rivalry that may have existed between the bodies. has been quite explicit in saying that it aims to stabilize corporate tax bases in the EU, including relaunching work to establish a Common Consolidated Corporate Tax Base (CCCTB). This points to a push for the introduction of the CCCTB, or at least CCTB (i.e., without the consolidation). It’s supposed to be a non-legislative initiative, so we might expect a communication that will set out ideas, with an argument that some kind of legislative underpinning in the form of a CCTB is essential. initiatives for 2015 there is a labor mobility package. Its objectives include the desire to try and achieve better coordination among EU social security systems. There’s also an initiative on a strategic framework for the energy union which will focus on promoting research and innovation and decarbonizing the energy mix but will also include the revision of the EU Emissions Trading System (ETS) as part of the legislative framework, post 2020. There has always been some tension between the ETS and the Commission has announced, as part of the 2015 workplan, that it will withdraw the current proposal for the will be interesting to see whether the Commission will come back to this within this strategic framework and try to tie in some developments on energy taxation. That’s not evident at this point but it’s one to watch. Trade strategy There’s also going to be a strategic review of the EU’s trade strategy. This will include a comprehensive review of the trade policy strategy and its contribution to jobs, growth and investment. It will cover all aspects of trade policy including bilateral, plurilateral and multilateral negotiations, as well as autonomous measures. It will be interesting both from a customs point of view and, indirectly, from a tax point of view as there are quite often tax elements to these trade agreements. The trade negotiations with the United States are clearly of great importance and will be pushed forward in 2015. The EC is trying to ensure this is done with greater disclosure and transparency. Whether one can negotiate effectively in an open forum remains to be seen. 10 Ibid. The outlook for global tax policy in 2015 | 19
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Czech Republic 2.5 Fiscal stimulus
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Denmark 2.2 Fiscal consolidation vs
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Denmark 2.7 Current tax policy and
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Finland 2.2 Fiscal consolidation vs
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Finland 2.8 Key tax policy changes
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France 2.2 Fiscal consolidation vs.
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France exceeds €1 million. Remune
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Germany 2 | 2015 tax policy outlook
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Germany 2.4 Tax policy outlook for
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Germany 2.9 Country position on OEC
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Greece 2.2 Fiscal consolidation vs.
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Hungary 2.2 Fiscal consolidation vs
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Hungary 2.5 Fiscal stimulus in 2015
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India 2 | 2015 tax policy outlook 2
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India 2.4 Tax policy outlook for 20
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India • Action 8 • The Indian t
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Ireland 2.2 Fiscal consolidation vs
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Ireland 2.8 Key tax policy changes
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Ireland 2.11 Consultations opened/c
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Italy 2 | 2014 tax policy outlook 2
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Italy 2.7 Current tax policy and ta
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Japan 2.2 Fiscal consolidation vs.
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Japan • • for each stock owne
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Luxembourg 2.10 Pending tax proposa
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Malaysia 2 | 2015 tax policy outloo
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Malaysia 2.3 Tax policy outlook for
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Malaysia 2.9 Country position on OE
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Mexico 2.2 Fiscal consolidation vs.
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Mexico 2.7 Current tax policy and t
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Netherlands • Additionally, the C
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Netherlands 2.4 Tax policy outlook
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Netherlands exemption, the tax tre
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New Zealand 2.2 Fiscal consolidatio
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Poland 2.2 Fiscal consolidation vs.
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Poland 2.5 Fiscal stimulus in 2015
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Portugal 2 | 2015 tax policy outloo
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Russia 2 | 2015 tax policy outlook
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Russia 2.4 Tax policy outlook for 2
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Russia 2.9 Country position on OECD
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Slovak Republic 2.2 Fiscal consolid
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Slovak Republic VAT, GST and sales
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South Africa 2.2 Fiscal consolidati
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South Africa 2.8 Key tax policy cha
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South Korea 2.2 Fiscal consolidatio
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Spain 2.2 Fiscal consolidation vs.
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Spain 2.5 Fiscal stimulus in 2015
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Switzerland 2.2 Fiscal consolidatio
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Thailand • Continued sluggish eco
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United Kingdom 2.2 Fiscal consolida
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United Kingdom 2.5 Fiscal stimulus
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United Kingdom 2.11 Consultations o
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United States • There is a desire
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United States 2.4 Tax policy outloo
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United States • Committee • C
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