Traduction de «système d'imposition à deux volets » (Français → Anglais) :

Finally, the Commission's decision that Belgium's "excess profit" ruling system was contrary to EU state aid rules was also based on derogations from the "arm's length principle". Profit allocation methods, which do not reflect economic reality: The Commission decided in August 2016 that Apple received illegal tax benefits in Ireland because the tax rulings endorsed a method to internally allocate profits within two Irish Apple group companies, which did not have any factual or economic justification. Inconsistent application of national law, giving rise to a discretionary double non-taxation ...[+++]: Today's investigation into Luxembourg's tax treatment of GDF Suez looks into an alleged inconsistent application of national tax law endorsed in the tax rulings, leading to double non-taxation.

As a result, changes should be made in the areas of financial sector reform, fiscal policy and structural reforms, in particular with regard to: (i) providing an updated plan for the gradual relaxation of external restrictions, which the authorities commit to starting only after the successful completion of the comprehensive assessment and a smooth transition to the Single Supervisory Mechanism (SSM); (ii) further measures to strengthen the banks' management of non-performing loans; (iii) a requirement to conclude the follow-up on the 2013 audit regarding individual financial institutions, impose sanctions if applicable, and make the f ...[+++]inal decision public; (iv) the provision of further measures to improve the Cooperative Group's operational capacity; (v) the adoption by the Council of Ministers of the new comprehensive framework establishing appropriate corporate and personal insolvency procedures, as well as the adoption by the House of Representatives of the amendments to the legal framework in relation to foreclosures of mortgaged properties (those are two prior actions), with details on the required elements of those two new frameworks; (vi) a revision of the 2014 primary fiscal deficit target of no more than EUR 210 million (1,3 % of GDP) to reflect the fiscal performance in the first half of 2014, the submission of a proposal ensuring the fiscal neutrality of the welfare system reform and the achievement of the 2015 fiscal deficit target, while the primary surplus target for 2017 was revised down to 2,5 % of the GDP in order to smooth the fiscal adjustment over 2017-2018; (vii) the setting of further steps to operationalise the privatisation process in the Cyprus Ports Authority and the Electricity Authority of Cyprus; (viii) the appointment of the new Commissioners and the two Assistant Commissioners of the new tax department, the establishment of a common taxpayer database, and the adoption of necessary regulations to make the enhanced collection powe ...

Although recent reforms show that the emphasis is clearly placed on tax systems, two features of the tax -benefit interaction can have a significant impact on labour supply.

It involves linking the two existing sub-regional water supply systems, enlarging the existing distribution network to cater for a larger population, improving some of the existing water treatment plants to ensure higher water quality, build a water desalinisation plant to supply fresh water to the Island of Culatra and building additional reservoirs and installing a distance-management system to improve the operational flexibility of the overall syste ...[+++]m.

Concerning the efforts to remove disincentives in the tax and benefit system, the Dutch government is pursuing a four-pronged tax reform policy, which represents a significant step forward to meet the first Council recommendation.

These problems may consist of difficulties in obtaining relief for double taxation because of the limited scope or complete absence of agreements on double taxation, discriminatory taxation rules and overlapping of different tax systems, as well as difficulties dealing with the tax legislation of two or more Member States and claiming tax reductions or reimbursements from another Member State.