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					                                                                                    EU Tax Alert
                                                                                    Edition 96 ● September 2011




                                             Advocate General considers Netherlands exit tax
                                             on companies in violation of EU law (National Grid
                                             Indus)
                                             On 8 September 2011, Advocate General Kokott delivered her Opinion
                                             in the National Grid Indus case (C-371/10). The case concerns the
                                             Netherlands exit taxation on companies that transfer their place of
                                             effective management to another Member State. According to the
                                             Advocate General, in the case at hand such exit taxation constitutes a
                                             violation of EU law. (See: Top News)


                                             Preliminary question referred to CJ on Belgian
                                             notional interest deduction (Argenta Spaarbank)
                                             On 24 June 2011, the Court of First Instance of Antwerp referred a
                                             preliminary question to the CJ regarding the compatibility of the Belgian
                                             notional interest deduction with the freedom of establishment (C-350/11).

            IN THIS EDITION:                 (See: Top News)


                                             Preliminary questions referred to the CJ on
            ●    Top News
                                             compatibility of French withholding tax on UCITS
            ●    State Aid / WTO
                                             with the free movement of capital
                                             On 4 July 2011, the Administrative Court of Montreuil referred several
            ●    Direct taxation
                                             cases (C-338-347/11) to the CJ requesting a preliminary ruling concerning
            ●    VAT
                                             the conditions under which the French withholding tax on UCITS can
            ●    Customs Duties, Excises
                                             be regarded as consistent with the free movement of capital. (See: Top
                 and other Indirect Taxes
                                             News)




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                                                                  E U Ta x A l e r t    Edition 96 ● September 2011          2




Contents
Top News                                                          Customs Duties, Excises and other
•	   Advocate	General	considers	Netherlands	exit	tax	on	          Indirect Taxes
     companies in violation of EU law (National Grid Indus)       •	   CJ	rules	on	the	CN	classification	of	kits	of	false	nails	
•	   Preliminary	question	referred	to	CJ	on	Belgian	notional	          (Pacific World Ltd and FDD International Ltd)
     interest deduction (Argenta Spaarbank)
•	   Preliminary	 questions	 referred	 to	 the	 CJ	 on	
     compatibility of French withholding tax on UCITS with
     the free movement of capital


State Aid / WTO
•	   CJ	confirms	Basque	tax	relief	measures	to	be	illegal	
     aid (Territorio Histórico de Vizcaya - Diputación Foral
     de Vizcaya and Others v Commission)


Direct taxation
•	   Preliminary	 question	 referred	 to	 the	 CJ	 on	 Finnish	
     rules denying the offset of capital losses incurred in
     another Member State against Finnish capital gains
     (K case)
•	   Commission	publishes	study	on	‘Transfer	Pricing	and	
     Developing Countries’
•	   Developments	 in	 the	 Netherlands:	 Lower	 Court	 in	
     Breda holds German individual not entitled to deduct
     from Netherlands tax base expenses related to private
     residence in Germany
•	   Developments	 in	 the	 Netherlands:	 Netherlands	
     Supreme	 Court	 decides	 that	 fine	 imposed	 by	
     Commission due to violation of EU competition law is
     not deductible


VAT
•	   CJ	 rules	 that	 Hungarian	 provision	 for	 the	 carrying	
     forward of excess VAT not allowed (Commission v
     Hungary)
•	   Portuguese	 car	 registration	 charges	 have	 to	 be	
     included in the taxable amount for VAT purposes (Lidl
     & Companhia)
•	   SWIFT	services	not	exempt	from	VAT	(Nordea Pankki
     Suomi Oyi)




attorneys ● tax lawyers ● civil law notaries
                                                                      E U Ta x A l e r t    Edition 96 ● September 2011          3




Top News
                                                                      postponed until the moment that the gain would have
                                                                      been taxable had the company not transferred its place of
                                                                      effective management.
Advocate General considers
Netherlands exit tax on companies in                                  The conclusion is in favour of the taxpayer. It seems that
violation of EU law (National Grid Indus)                             it	can	hardly	be	justified	under	EU	law	to	levy	exit	taxes	
On 8 September 2011, Advocate General Kokott delivered                without the possibility of postponing the payment and
her Opinion in the National Grid Indus case (C-371/10).               without the possibility to take into account later losses.
The Opinion concerns the Netherlands exit taxation                    Although the CJ still has to decide the case, internationally
on companies that transfer their place of effective                   acting companies may contemplate restructurings taking
management to another Member State, but also deals                    into account the possibility of transferring the place of
with exit taxation in general. According to the Advocate              effective management of their group companies between
General, in the case at hand such exit taxation constitutes           Member States without the burden of immediate exit
a violation of EU law. The verdict of the Court of Justice            taxation. Further developments are expected in this
(’CJ’) in this case is expected around March 2012.                    matter, as the Commission has referred several Member
                                                                      States to the CJ in infringement procedures on account
In 2000 National Grid Indus BV, a company incorporated                of their company exit tax rules. These cases are currently
under Netherlands law, transferred its place of effective             pending before the CJ (see EU Tax Alert edition no. 71,
management to the UK without maintaining a permanent                  October 2009; EU Tax Alert edition no. 86, December
establishment in the Netherlands. The only assets of the              2010).
company were receivables in GBP which, at the moment
of the transfer of seat, contained unrealised currency                Preliminary question referred to CJ
gains. The transfer of the place of effective management              on Belgian notional interest deduction
of the company triggered Netherlands corporation tax                  (Argenta Spaarbank)
(an	 ‘exit	 tax’)	 of	 such	 currency	 gains.	 In	 the	 course	 of	   On 24 June 2011, the Court of First Instance of Antwerp
the following court procedure, the Court of Appeal in                 referred a preliminary question to the CJ regarding the
Amsterdam referred the case to the CJ as it had doubts                compatibility of the Belgian notional interest deduction
whether such exit taxation was compatible with EU law.                with the freedom of establishment set out under Article
                                                                      49 TFEU (previously Article 43 EC). The case is known
First, the Advocate General concluded that a company                  as the Argenta Spaarbank case (C-350/11).Under article
that is established under the laws of a Member State                  205ter of the Belgian Corporate Income Tax Code, the
can invoke the freedom of establishment under Article                 equity amount that is used as the basis on which the
49 of Treaty on the Functioning of the European Union                 notional interest deduction is calculated is reduced with
(‘TFEU’)	if	such	Member	State	imposes	an	exit	tax	without	            the net book value of assets attributable to permanent
the option to (i) postpone the tax payment and (ii) to take           establishments situated in other EU Member States.
into account later losses on the hidden reserves of the               However,	 assets	 attributable	 to	 a	 Belgian	 permanent	
assets transferred. In addition, she is of the opinion that           establishment are taken into account when calculating
immediate exit taxes levied on companies moving their                 that basis.
place of effective management to another Member State                 In the case concerned, the taxpayer (Argenta Spaarbank)
constitute a restriction on the freedom of establishment.             is resident in Belgium and has a permanent establishment
In	her	view,	such	restriction	can	only	be	justified	if	it	is	not	     in the Netherlands. The income of the permanent
reasonably possible to keep track of the hidden reserves              establishment is tax exempt in Belgium. For the calculation
of the assets transferred. Finally, the Advocate General              of the notional interest deduction its investments in the
dealt	with	the	specific	case	of	the	transfer	of	receivables	          Netherlands permanent establishment are not taken
that contain unrealised foreign currency gains. She                   into account, whereas they would have been taken into
concluded that even if such foreign currency gains are                account if the investments had been made in a Belgian
not capable of being taken into account for tax purposes              permanent establishment. Because the Netherlands does
in the Member State to which the company transferred its              not provide for notional interest deduction, the taxpayer
place of effective management, an immediate exit taxation             cannot claim an advantage in the Netherlands either.
violates EU law. In her view, such exit taxation should be

attorneys ● tax lawyers ● civil law notaries
                                                                  E U Ta x A l e r t     Edition 96 ● September 2011            4




The Court of First Instance at Antwerp has now referred a         The	first	incentive	allowed	for	a	reduction	of	the	corporate	
question for preliminary ruling to the CJ asking whether or       tax base for newly established companies of 99%, 75%,
not Article 43 EC precludes a national tax regulation which       50% and 25% for four years. This was conditional upon
provides that a taxpayer subject to unlimited tax liability for   making a minimum investment of nearly EUR 0.5 million,
the	calculation	of	its	taxable	profit	cannot	claim	a	notional	    having a minimum capital of at least EUR 120,000 and
interest deduction for the positive difference between the        creating at least 10 jobs. The second incentive provided
net book value of the assets of a permanent establishment         for a 45% investment tax credit for certain investments
which the taxpayer has in another EU Member State and             over EUR 15 million. The Commission’s 2001 decisions
the liabilities which can be attributed to that permanent         were the result of investigations started in 1999 following
establishment, whereas a notional interest deduction can          complaints from 1996 and 1997. The CJ pointed out
be claimed if this positive difference can be attributed to a     that	 the	 Historical	 Territories	 themselves	 could	 not	 rely	
Belgian permanent establishment.                                  on legitimate expectations in order to justify their failure
                                                                  to recover aid, as it would render recovery decisions
Note that the Commission already sent to Belgium, on              ineffective. The Commission’s inaction from 1996 to 2000
27 March 2009, a letter of formal notice in this regard           could not constitute an implied approval of aid, given that
taking	the	first	step	of	the	infringement	procedure	under	        the Territories had failed to properly notify the measures
Article 258 TFEU.                                                 and showed lack of cooperation with the Commission’s
                                                                  investigation. Even though the preliminary investigation
Preliminary questions referred to the CJ                          took a little more than three years, the CJ found that this
on compatibility of French withholding                            was not excessively long having regard to the fact the
tax on UCITS with the free movement of                            Commission was able to obtain the information necessary
capital                                                           to open a formal investigation only by gradually examining
On 4 July 2011, the Administrative Court of Montreuil             the schemes. It was not shown that the complaints as such
referred several cases (C-338-347/11) to the CJ requesting        contained the information necessary for the Commission
a preliminary ruling regarding the following questions:           to proceed.


‘(1)	 Must	 the	 situation	 of	 the	 shareholders	 be	 taken	     This decision again indicates that in the absence of proper
    into account together with that of undertakings for           notification,	 the	 perceived	 inactivity	 by	 the	 Commission	
    collective investments in transferable securities             does not exclude a formal investigation to be started
    (UCITS)?                                                      a	 few	 years	 later.	 Without	 such	 notification	 and	 hence,	
(2) If so, what are the conditions under which the                without the necessary information being provided by the
    withholding tax at issue may be regarded as consistent        Member State (on behalf of the autonomous authority),
    with the principle of free movement of capital?’              the Commission may need a substantial amount of time to
                                                                  complete its preliminary analysis before deciding whether


State Aid/WTO
                                                                  and how to proceed.



CJ	confirms	Basque	tax	relief	measures	                           Direct Taxation
to be illegal aid (Territorio Histórico de
Vizcaya - Diputación Foral de Vizcaya                             Preliminary question referred to the CJ on
and Others v Commission)                                          Finnish rules denying the offset of capital
On	28	July	2011,	the	CJ	confirmed	the	(then)	Court	of	First	      losses incurred in another Member State
Instance’s judgments upholding a series of Commission             against Finnish capital gains (K case)
decisions from 2001 with regard to two tax incentives             On 28 June 2011, the Supreme Administrative Court of
introduced	by	the	three	Historical	Territories	of	the	Basque	     Finland referred a question for a preliminary ruling to the
Country (Álava, Vizcaya and Guipúzcoa) in Spain in the            CJ in the K case (C-322/11) concerning the compatibility
mid-1990’s (Joined Cases C-471/09 P to C-473/09 P and             with the free movement of capital set out in Article 63 TFEU
C-474/09 P to C-476/09 P).                                        of the Finnish tax provisions which preclude the offset of




attorneys ● tax lawyers ● civil law notaries
                                                                     E U Ta x A l e r t   Edition 96 ● September 2011          5




capital losses incurred on immovable property situated in            purchase of this house. According to Netherlands law,
another Member State against capital gains derived from              the deemed income related to the dwelling would have
transfer	 of	 shares	 taxable	 in	 Finland.	 Specifically,	 the	     amounted to EUR 950. Interested Party had not opted to
Finnish court asked the CJ the following question:                   be treated as a Netherlands resident taxpayer (unlimited
                                                                     tax liability), but did want to deduct the negative income
‘Must	Articles	63	TFEU	and	65	TFEU	be	interpreted	as	                (deemed income minus interest expenses) related to
precluding national legislation under which a person                 the house based on the CJ’s judgment in Renneberg
with general liability to tax in Finland cannot deduct               (C-527/06).
a loss incurred on the transfer of immovable property
situated in France from gains on the transfer of shares              The tax inspector disagreed, as in his view, Interested
taxable in Finland, whereas a person with general                    Party and his wife together did not meet the Schumacker
liability to tax in Finland may on certain conditions                criterion.	The	Lower	Court	agreed	with	the	tax	inspector	
deduct a loss on the transfer of equivalent immovable                noting that it follows from Renneberg that the income
property situated in Finland from gains on transfer?’                of both partners should be taken into account. As the
                                                                     wife earned her income outside the Netherlands, the
Commission	publishes	study	on	‘Transfer	                             Schumacker	 criterion	 was	 not	 met.	 The	 Lower	 Court	
Pricing and Developing Countries’                                    concluded that the negative income related to the
On 27 July 2011, the Commission published a study on                 dwelling in Germany cannot be deducted for Netherlands
‘Transfer	 Pricing	 and	 Developing	 Countries’	 the	 aim	 of	       tax purposes. The Interested Party would have had the
which is to recommend suitable approaches for supporting             possibility to opt to be treated as a Netherlands resident
developing countries in the adoption and implementation              taxpayer.
of transfer pricing (TP) rules in line with international
standards in order to increase tax revenue. The study                Developments in the Netherlands:
focuses	 on	 four	 countries,	 namely	 Ghana,	 Honduras,	            Netherlands Supreme Court decides
Kenya and Vietnam, all of which are at different stages              that	fine	imposed	by	Commission	due	
with	 regard	 to	TP	 legislation	 and	 based	 on	 the	 findings	     to violation of EU competition law is not
makes recommendations for donor support to developing                deductible
countries.                                                           On 12 August 2011, the Netherlands Supreme Court
                                                                     issued its judgment in the case of X BV on the deductibility
Developments in the Netherlands:                                     of	a	fine	imposed	by	the	European	Commission	due	to	a	
Lower	Court	in	Breda	holds	German	                                   violation of the EU competition law.
individual not entitled to deduct from
Netherlands tax base expenses related                                On 11 June 2009, as a prelude and concerning the same
to private residence in Germany                                      facts, the CJ had rendered its judgment in the X BV case
On	 10	 June	 2011,	 the	 Lower	 Court	 in	 Breda	 decided	          (C-429/07) concerning the interpretation of Article 15(3) of
that a German individual was not entitled to deduct from             Council Regulation (EC) No 1/2003 of 16 December 2002
its Netherlands tax base expenses related to a private               on the implementation of the rules on competition laid
residence in Germany.                                                down in Articles 81 and 82 EC. The question in this case
                                                                     was whether the Commission is competent to submit, on its
This case involved a German resident (Interested Party)              own initiative, written observations in proceedings relating
and his wife. The Interested Party was employed by                   to	the	deductibility	of	a	fine	for	infringement	of	Community	
a company resident in the Netherlands where he also                  competition	law	from	the	(taxable)	profit	realised	by	the	
performed his employment. As such, he was subject to                 party concerned in 2002, which was imposed by the
non-resident	 taxation	 in	 the	 Netherlands.	 His	 wife	 also	      Commission on X KG and (partially) passed on to the
derived employment income, but outside the Netherlands.              party concerned. The CJ ruled that the Commission was
Together, they owned a dwelling in Germany which                     competent to submit written observations before national
could be considered their primary residence, according               courts in these matters (see EU Tax Alert edition no. 68,
to Netherlands standards. An amount of EUR 7,049 in                  July 2009).
interest	 was	 paid	 with	 respect	 to	 a	 loan	 to	 finance	 the	



attorneys ● tax lawyers ● civil law notaries
                                                                   E U Ta x A l e r t     Edition 96 ● September 2011            6




On	12	August	2001,	the	Supreme	Court	held	that	the	fine	           to carry forward excess amounts of VAT if that excess
was	not	deductible	because	the	entire	fine	formed	a	non-           amount relates to incurred VAT that has not actually been
deductible administrative penalty, irrespective of the fact        paid by the taxpayer to the supplier.
that the amount of the penalty was based on the additional
turnover obtained through the violation.                           Finally,	according	to	the	CJ	the	Hungarian	provision	may	
The	Court	deemed	it	irrelevant	that	the	fine	was	imposed	          also result in excess amounts of VAT having to be carried
on a German company which had on-charged part of that              forward more than once to the following tax period, as a
fine	to	a	Netherlands	group	company,	and	that	the	income	          result of which, taxpayers cannot obtain a refund of that
thereon in Germany was subject to taxation. Finally, the           excess VAT within a reasonable period. According to the
Court rejected the argument that the non-deductibility             CJ, this is also not in line with the EU VAT Directive.
is incompatible with the non-discrimination principle of
Article	14	of	the	European	Convention	of	Human	Rights	             Portuguese car registration charges
(‘ECHR’)	and	Article	26	of	the	International	Covenant	on	          have to be included in the taxable
Civil	and	Political	Rights	(‘ICCPR’)	and	Article	1	of	the	First	   amount for VAT purposes (Lidl &
Protocol	to	the	ECHR.                                              Companhia)
                                                                   On 28 July 2011, the CJ gave its judgment in the case of


VAT
                                                                   Lidl & Companhia (C-106/10).


                                                                   Lidl	 &	 Companhia	 purchased	 two	 motor	 vehicles.	 The	
CJ	rules	that	Hungarian	provision	for	                             taxable amount on the basis of which VAT had been
the carrying forward of excess VAT not                             calculated included the vehicle tax, so-called ISV charges,
allowed (Commission v Hungary)                                     with respect to importation of the vehicles into the national
On 28 July 2011, the CJ gave its judgment in the                   territory	 of	 Portugal.	 In	 this	 regard,	 Lidl	 &	 Companhia	
Commission v Hungary case (C-274/10). The case                     claimed that the inclusion of the ISV charges in the taxable
concerned an infringement procedure that had been                  amount gave rise to the payment of an excessive amount
initiated	by	the	Commission	against	Hungary	with	respect	          of VAT, and it sought repayment of that excess amount.
to a national provision for the carrying forward of excess         In the subsequent proceedings, the Supremo Tribunal
VAT. On the basis of this provision taxable persons were           Administrativo decided to refer preliminary questions to
required to carry forward excess amounts of VAT to the             the CJ.
following tax period if that excess included an amount of          The	 CJ	 firstly	 considered	 that	Article	 78	 of	 the	 EU	 VAT	
incurred input VAT which had not actually been paid yet by         Directive indicates that taxes, duties, levies and charges,
the taxpayer to its supplier. According to the Commission,         excluding VAT itself, are to be included in the taxable
such a provision was not in line with the EU VAT Directive.        amount. If, however, amounts have been received from
As a preliminary remark, the CJ indicated that the Member          the customer for expenses incurred in the name and on
States have certain freedom on the basis of Article 183 of         behalf of the customer, then such amounts are not to be
the EU VAT Directive in determining the conditions for the         included in the taxable amount on the basis of Article 79
refund of excess VAT such conditions, however, may not             of the EU VAT Directive.
undermine	the	principle	of	fiscal	neutrality	by	making	the	
taxable person bear (part of) the burden of the VAT.               In respect of these considerations the CJ indicated that
                                                                   the ISV is payable by registered operators, authorized
Moreover, the CJ indicated that VAT becomes due and                operators and private individuals who release vehicles
deductible under the system of the EU VAT Directive                liable to the tax for consumption. Accordingly, the CJ
when a transaction has been carried out, and that this,            concluded that the ISV was due by the supplier of the
in principle, is independent of the fact whether or not the        vehicles and that it, therefore, had not been paid on behalf
consideration due for the transaction has actually been            of	Lidl	&	Companhia	(being	the	purchaser	of	the	vehicles).	
paid or received. As a result, the CJ concluded that the EU        As a consequence, a direct link exists between the supply
VAT	Directive	does	not	allow	Hungary	to	require	taxpayers	         of the vehicles and the ISV charges. Moreover, the CJ




attorneys ● tax lawyers ● civil law notaries
                                                                  E U Ta x A l e r t     Edition 96 ● September 2011           7




indicated that the chargeable event and the liability to          of the messaging services and does not extend to
pay ISV predate the registration operation itself. The CJ         specific,	essential	elements	of	the	financial	transactions.	
therefore concluded that the ISV must be regarded to be           Therefore, it does not have a bearing on the conclusion
directly linked to the supply of the vehicles falling within      that the services rendered by SWIFT do not fall under the
its ambit and has to be included in the taxable amount            VAT exemption of Article 13B(d)(3) and (5) of the Sixth EU
for VAT purposes in accordance with Article 78 of the EU          VAT Directive.
VAT Directive.


SWIFT services not exempt from VAT                                Customs Duties,
(Nordea Pankki Suomi Oyi)
On 28 July 2011, the CJ gave its judgment in the Nordea           Excises and other
                                                                  Indirect Taxes
Pankki Suomi Oyi case (C-350/10).


Nordea	 Pankki	 Suomi	 Oyi	 (‘Nordea’)	 is	 a	 merchant	
bank that incurred considerable expenses for services             CJ	rules	on	the	CN	classification	of	kits	
purchased from Society for Worldwide Interbank Financial          of false nails (Pacific World Ltd and
Telecommunication	–	SWIFT	SC	(‘SWIFT’).	The	services	             FDD International Ltd)
rendered by SWIFT consist of electronic messaging                 On 28 July 2011, the CJ gave its judgment in the Pacific
services	 for	 financial	 institutions.	 SWIFT	 processes,	 in	   World Ltd and FDD International Ltd case (C-215/10).
particular, messages concerning interbank payments and            The case concerns the validity of Regulation (EC)
transactions in securities.                                       No 1417/2007 based on which, kits of false nails
Nordea declared and paid reversed VAT on the SWIFT                are	classified	under	Combined	Nomenclature	(CN)	
services. Subsequently, it asked for a refund of the VAT          subheading 3926 9097. The kits concerned normally
on the grounds that the services rendered by SWIFT were           contain a set of false nails of different sizes, designed to
VAT exempt on the basis of Article 13B(d)(3) and (5) of           be	bonded	to	the	natural	fingernail	or	toenail,	a	bonding	
the Sixth EU VAT Directive. The Finnish tax authorities           solution specially designed to bind false nails to natural
denied the refund. Eventually the case ended up before            nails, and other tools such as a manicure stick and
the Supreme Administrative Court of Finland, which Court          application tool.
decided to refer preliminary questions to the CJ.
                                                                  It was discussed whether the goods involved should be
The CJ indicated on the basis of settled case law that            classified	under	CN	sub	heading	3304	3000	as	‘manicure	
services	 entrusted	 to	 operators	 external	 to	 financial	      or pedicure preparations’ or under CN subheading 3926
institutions are exempt from VAT provided that those              9097	as	‘other	articles	of	plastic’.	CN	sub	heading	attracts	
services	fulfil	in	effect	specific	and	essential	functions	of	    0% customs duty to be paid over the customs value of the
the	 financial	 transactions	 as	 indicated	 in	Article	 13B(d)   goods; CN subheading 3926 9097 attracts 6.5% customs
(3) and (5) of the Sixth EU VAT Directive. In this regard,        duty.
the CJ concluded that the SWIFT services cannot be
characterized as such transactions because they merely            The CJ ruled that the CN must be interpreted as meaning
concern electronic messaging services simply intended             that Commission Regulation (EC) No 1417/2007 of
to transmit information, and which in themselves, do not          28	November	2007	concerning	the	classification	of	certain	
have the effect of transferring funds or securities.              goods in the Combined Nomenclature is valid insofar as
                                                                  it	classifies	the	false	nails	and,	thereby,	the	false	nail	sets	
Moreover, in respect of Nordea’s claim that the services          under CN subheading 3926 90 97.
rendered by SWIFT are not merely technical services
due	 to	 the	 extensive	 financial	 responsibility	 of	 SWIFT	
for the transmission of the messages, the CJ indicated
that this responsibility is limited to the technical aspects




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                                                                        E U Ta x A l e r t      Edition 96 ● September 2011   8




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