Recitals
- Recital (1)Council Directive (EU) 2022/2523 implements the agreement reached on 8 October 2021 by the OECD/G20 Inclusive Framework (OECD/G20 IF) on…
- Recital (2)Directive (EU) 2022/2523 already establishes the rules for filing Top-up tax information returns and outlines broadly the information…
- Recital (3)It is therefore appropriate to amend Council Directive 2011/16/EU to establish new rules on the automatic exchange of information to…
- Recital (4)While the general rule is that a constituent entity files a Top-up tax information return with its tax administration (local filing),…
- Recital (5)The new rules on automatic exchange of information should enable the central filing of the Top-up tax information return in accordance with…
- Recital (6)Member States should take the necessary measures to require the filing constituent entities of MNE groups to use the standard template set…
- Recital (7)When a Member State receives a Top-up tax information return from the ultimate parent entity or the designated filing entity of an MNE…
- Recital (8)The Member State of the ultimate parent entity of the MNE group should receive the full Top-up tax information return. The Implementing…
- Recital (9)Jurisdictional sections should be provided to the Member State with taxing rights under Directive (EU) 2022/2523, including the QDTT, in…
- Recital (10)Directive (EU) 2022/2523 allows Member States in which no more than twelve ultimate parent entities of groups within the scope of that…
- Recital (11)In order to ensure uniform conditions for the implementation of this Directive and in particular, for the automatic exchange of information…
- Recital (12)The receiving competent authority should notify the sending competent authority when there is reason to believe that the information…
- Recital (13)If a competent authority does not receive an exchange that was expected pursuant to a notification from an MNE group, it should notify the…
- Recital (14)If the Top-up tax information return has not been filed centrally by the ultimate parent entity or the designated filing entity of an MNE…
- Recital (15)Directive 2011/16/EU, including Annex VII thereto, as amended by this Directive, should be read together with Directive (EU) 2022/2523. The…
- Recital (16)In implementing this Directive, Member States should use the Multilateral Competent Authority Agreement on the Exchange of GloBE…
- Recital (17)The standard template for the Top-up tax information return set out in this Directive ensures that the information and tax calculations…
- Recital (18)To ensure the exchange of information regarding joint ventures and equal treatment, in rare cases where a parent entity of a large-scale…
- Recital (19)Furthermore, recognising the need to provide a complete legal framework, so that it covers the amendments introduced into Directive…
- Recital (20)Since the objective of this Directive, namely to provide the framework for the operational implementation of the filing obligations laid…
- Recital (21)Given that Member States need to act within a very short period of time to begin transposition of rules on the Top-up tax information…
- Recital (22)Directive 2011/16/EU should therefore be amended accordingly,
1 of this act's 1 annex has no parsed text here (image-only or non-standard attachments) — see EUR-Lex for those. Text as published in the Official Journal; for the authentic version, see EUR-Lex.
