Traduction de «subvention en remplacement d'impôt » (Français → Anglais) :

(i) whereas increased transparency regarding the activities of large MNC, and in particular regarding profits made, taxes on profit paid, subsidies received and tax returns, number of employees and assets held is essential for ensuring that tax administrations tackle BEPS efficiently; whereas a right balance needs to be struck between transparency, personal data protection and commercial sensitivity, as well as considering the impact on smaller business ...[+++]es; whereas one vital form for this transparency to take is country-by-country reporting; whereas any Union proposals for country-by-country reporting should in the first instance be based on the OECD template; whereas it is possible for the Union to go further than the OECD guidelines and make such country-by-country reporting mandatory and public, and the European Parliament voted in favour of full public country-by-country reporting in its amendments adopted on 8 July 2015 on the proposal for a revised Shareholder Rights Directive; whereas the European Commission conducted a consultation on this subject between 17 June and 9 September 2015 in order to explore different options for the implementation of country-by-country reporting; whereas 88% of those who responded publicly to that consultation said that they supported public disclosure of tax-related information by enterprises;

(5) It is necessary to ensure that interest and royalty payments are subject to tax once in a Member State and that the benefits of the Directive should only be applicable when the income derived from the payment is effectively subject to tax in the Member State of the receiving company or in the Member State where the recipient permanent establishment is situated, without there being the possibility of exemption or a substitution or replacement by payment of another tax.

1. Interest or royalty payments arising in a Member State shall be exempt from any taxes imposed on those payments in that Member State, whether by deduction at source or by assessment, provided that the beneficial owner of the interest or royalties is a company of another Member State or a permanent establishment situated in another Member State of a company of a Member State and is effectively subject to tax on the income deriving from those payments in that other Member State at a rate not lower than 70% of the average statutory corporate tax rate applicable in the Member States, without there being the possibility of exemption or a substitution or replacement by p ...[+++]ayment of another tax .

(5) It is necessary to ensure that interest and royalty payments are subject to tax once in a Member State and that the benefits of the Directive should only be applicable when the income derived from the payment is effectively subject to tax in the Member State of the receiving company or in the Member State where the recipient permanent establishment is situated, without there being the possibility of exemption or a substitution or replacement by payment of another tax .

Pursuant to point (h), indirect tax rebate schemes can constitute an export subsidy to the extent that they result in exemption, remission or deferral of prior-stage cumulative indirect taxes in excess of the amount of such taxes actually levied on inputs that are consumed in the production of the exported product.

Where it is alleged that an indirect tax rebate scheme, or a drawback scheme, conveys a subsidy by reason of over-rebate or excess drawback of indirect taxes or import charges on inputs consumed in the production of the exported product, the Commission must normally first determine whether the government of the exporting country has in place and applies a system or procedure to confirm which inputs are consumed in the production of the exported product and in what amounts.