Case C‑117/11 of Purple Parking Ltd. Facts The UK-registered companies Purple Parking Ltd. and Airparks Services Ltd. provided “off-airport” parking and “off-airport park-and-ride” services.
RLRE Tellmer Property sro („Tellmer”) case (Case C-572/07) Facts Tellmer, which is headquartered in the Czech Republic, is the owner of rented apartment blocks.
CPP case (Case C-349/96) Facts Card Protection Plan Ltd. („CPP\"),which is headquartered in the United Kingdom, supplies a service covering the indemnification of cardholders against financial loss in the event of loss or theft of their bank cards and other damages arising on their travels (such as damages related to the finding of lost luggage) under a so-called “Card Protection Plan”.
This March, the OECD Global Forum on Transparency and Exchange of Information (hereinafter: Global Forum) approved the entry of Switzerland to phase 2 of the so-called “peer review” and concluded Hungary’s phase 2 review in which our country received the rating “largely compliant”.
Companies may request preliminary rulings regarding the VAT liabilities relating to cross-border transactions from the tax authorities of the Member States participating in the CBR pilot project. Currently, rulings may be requested in 15 member states (Belgium, Cyprus, the United Kingdom, Estonia, Finland, France, the Netherlands, Latvia, Lithuania, Hungary, Malta, Portugal, Spain, Slovenia and Sweden).
Two of the BEPS actions published so far (Actions 8 and 13) deal with transfer pricing. From these two, Action 13 specifically summarizes the BEPS guidance on transfer pricing documentation and country-by-country reporting.
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.