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Samantha Schmitz-Merle Luxembourg Undertakings for Collective Investment (UCIs) may perform different types of investments in many different countries and may as such realise different types of income from different countries. The return on these various investments may be subject to withholding tax in the source country. The double tax treaties (DTTs) concluded by Luxembourg provide, among other provisions, reduced withholding tax rates. The question arises as to whether and if yes, under which conditions, Luxembourg UCIs may benefit from these reduced rates. Obtaining a tax residence certificate (TRC) from the jurisdiction of establishment of the fund is very often one of the requirements. The Luxembourg tax authorities have released a circular, the aim of which is to confirm under which conditions Luxembourg UCIs (SICAVs, SICAFs and FCP) may obtain a TRC. The circular also clarifies the position of the Luxembourg tax authorities and the foreign authorities towards DTT benefits for Luxembourg UCIs. The circular covers SICAVs, SICAFs & FCP, both within the meaning of the Luxembourg 2010 law on Undertakings for Collective Investments and within the meaning of the 2007 Law on Specialised Investment Funds (SIFs). A TRC can be obtained under certain conditions for SICAVs/SICAFs (type 1 tax residence certificate) as well as for FCPs (type 2 tax residence certificate).

Georgia Grigoriou Greek law 89/1967 (L.89), as now in force, includes provisions aiming to attract foreign investments to Greece by granting the qualifying entities a special cost–plus tax regime (pre-agreed with the tax authorities), following a special advance pricing procedure. Such regime has been in force since 2006. Specifically, this special tax regime applies to local entities and branches of foreign enterprises, exclusively engaged in providing certain qualifying services (for example, consulting, accounting, advertising, marketing, data processing and/or R&D services) to other associated entities established outside Greece and to their head offices abroad. A L.89 office is established after obtaining a special license granted by the Ministry of Finance (MoF) and must employ at least four persons while its operating expenses must be at least €100,000 per year and covered by direct funding from the company established outside Greece.

Rajendra Nayak

Mark Galea Salomone

Bob van der Made When it presented its annual Commission Work Programme for 2015 on December 16 2014, the European Commission (EC) stated that it would also clamp down on tax evasion and tax avoidance to ensure that taxes are paid in the country where profits are generated. Initially, the Juncker Commission's priorities focused heavily on the theme of 'jobs and growth'. However, under pressure from the European Parliament and media reports in the third quarter of 2014, the Commission has made the fight against tax evasion and avoidance one of its top political priorities for 2015. A number of important legislative and non-legislative EC initiatives have therefore been rolled out from March onwards. On March 18 2015, the EC published a new 'tax transparency package' consisting of three elements.

Chris Harker

Ramazan Biçer

Mario Ortega Calle

Romanian firm Nestor Nestor Diculescu Kingston Peterson has announced the appointment of two new tax directors: Adina Vizoli and Sorin Mociofan.

Ministers of culture from France, Germany, Italy and Poland have demanded the EU evolves its legislation to allow e-books to be taxed in the same way as physical books.