Editorial. Inside. Volume 2 Issue 4 January 2013 European Tax Brief. European Union: Commission launches action plan against fraud and evasion.

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1 Volume 2 Issue 4 January 2013 European Tax Brief Tax PRECISE. PROVEN. PERFORMANCE. Editorial Welcome to the latest issue of Moore Stephens European Tax Brief. This newsletter summarises important recent tax developments of international interest taking place in Europe and in other countries within the Moore Stephens European Region. If you would like more information on any of the items featured, or would like to discuss their implications for you or your business, please contact the person named under the item(s). The material discussed in this newsletter is meant to provide general information only and should not be acted upon without first obtaining professional advice tailored to your particular needs. European Tax Brief is published quarterly by Moore Stephens Europe Ltd in Brussels. If you have any comments or suggestions concerning European Tax Brief, please contact the Editor, Zigurds Kronbergs, at the MSEL Office by at zigurds. kronbergs@moorestephens-europe.com or by telephone on +32 (0) We take this opportunity of wishing all our readers a happy and prosperous New Year. Inside European Union: Commission launches action plan against fraud and evasion. Page 2 France: 75% tax rate struck down. Page 4 Germany: Swiss tax agreement rejected. Page 5 Netherlands: Court approves 150 km rule. Page 7 Switzerland: Lump-sum tax opponents secure tax referendum. Page 9 United Kingdom: Mixed tax bag from Autumn Statement. Page 10

2 European Union Commission launches action plan against fraud and evasion On 6 December, the European Commission announced a wideranging number of actions and recommendations to combat tax evasion and tax avoidance and promote tax good governance. Against a background in which it estimates that tax evasion and tax avoidance lose the European Union and its Member States around EUR 1 million million (EUR ) a year, the Commission believes that a strong and cohesive EU stance is a necessary adjunct to tougher national measures. As part of the Action Plan, the Commission has adopted two Recommendations to encourage Member States to take immediate and coordinated action on tax havens and aggressive tax planning. As regards tax havens, the Commission recommends that Member States adopt a common set of criteria to identify third countries not meeting minimum standards of good governance in tax matters (such as automatic exchange of information). Non-compliant countries should be blacklisted and double tax treaties with them renegotiated, suspended or concluded. Member States should also take other actions, within European law, to discourage business with such jurisdictions. Technical assistance should be offered to those countries wishing to be compliant but lacking the means or expertise. With respect to aggressive tax planning, the Commission recommends that Member States include a provision in their double tax treaties to remove the possibility of exploiting specifically identified types of double non-taxation (e.g. the use of hybrid entities and exploitation of mismatches) and introduce a common general anti-abuse rule. Review anti-abuse provisions in key tax Directives (parentsubsidiary, interest and royalty, mergers). Develop a common methodology and guidelines for tracing money flows. The Commission also wishes to see Member States reinvigorate the work of the EU Code of Conduct on business taxation and recommends that it be extended to include special tax régimes for wealthy individuals. If the Commission considers that solutions to remove particular mismatches allowing double non-taxation are not agreed and implemented in a timely and effective way, it is prepared to come forward with legislative proposals for action. In the medium to longer term, the Commission will: Develop a European taxpayers code based on existing good administrative practice in Member States, to enhance cooperation, trust and confidence between taxpayers and tax administrations and to ensure transparency on the rights and obligations of taxpayers. Consult on the creation of an EU-wide taxpayer identification number (TIN), whether in the form of a unique European TIN or of an addition of an EU identifier to existing national TINs. It has already launched a TIN on Europa web portal, providing samples of official identity documents containing national TINs and enabling third parties to check whether a TIN they have been quoted is structurally correct (as can now be done with VAT registration numbers via VIES). The Commission is urging the Council of Ministers to approve the amendments it has proposed to the Savings Taxation Directive, sign and conclude the anti-fraud and tax cooperation agreement with Liechtenstein, and grant it a mandate to negotiate the corresponding changes to the parallel agreements with Andorra, San Marino and Switzerland. The Commission will continue to work closely with the OECD and G20 and considers this Action Plan to be a robust EU contribution to the international debate on evasion and avoidance. The Action Plan will now be presented to ECOFIN (the Council of Finance Ministers) and the European Parliament. 2

3 France and Luxembourg asked to amend VAT rate on e-books The European Commission has formally requested by reasoned opinion that France and Luxembourg remove their reduced rate of value added tax on e-books. The VAT rate in France on e-books is 7% and that in Luxembourg is 3%. The Commission considers that e-books constitute electronic services, to which reduced rates may not be applied under the VAT Directive. In the Commission s opinion, this causes a severe distortion of competition to the detriment of booksellers in the other 25 Member States, especially as e-books may easily be purchased cross-border. Under the reasoned-opinion procedure, Member States have one month in which to amend their law accordingly, or face the prospect of eventual litigation in the European Court. zigurds.kronbergs@moorestephens-europe.com VAT partial exemption turnover method not exclusive The European Court has ruled that when calculating the deductible proportion of input tax on general overheads where there are both exempt and non-exempt activities, methods other than the turnover method may be used. In the German case Finanzamt Hildesheim v BLC Baumarkt GmbH & Co KG (Case C 511/10), the taxpayer, a limited partnership, constructed a building consisting of commercial premises on the ground floor and residential apartments on the upper floor. The rent for the ground floor was subject to VAT whereas the rents on the residential apartments were exempt. In calculating the deductible proportion of input VAT on the construction of the building (and hence not directly attributable to either the taxable or the exempt rents), Baumarkt used turnover (i.e. the ratio that the commercial rents bore to the total rents). The tax authorities, however, insisted on the use of floor space (i.e. the ratio that the floor space of the commercial premises bore to the floor space of the entire building). referred the matter to the European Court on the question of whether the tax authorities were allowed to prescribe any method other than the turnover method for a mixed-use building. The Court concluded that whereas the primary method was the turnover method, Member States were at liberty to derogate from that method and prescribe alternative methods, such as used in the present case, if the alternative method guaranteed that the deductible proportion of input tax would be more precisely determined. The case was taken on the wording of Article 17(5) of the old Sixth VAT Directive. Although the wording of the replacement provision (Article 173) of the 2006 VAT Directive is slightly different, the judgment of the Court is equally valid under existing legislation. The resulting litigation reached the Federal Finance Court (Bundesfinanzhof), which t.vanden.berg@mth.nl 3

4 France 75% tax rate struck down The much publicised 75% rate of tax that was to be imposed on the amount of taxable income in excess of EUR 1 million has been ruled unconstitutional by France s Constitutional Court (Conseil Constitutionnel), in a decision published on 29 December. The case was brought by opposition members of parliament who contested the constitutionality of several provisions both in the Finance Act 2012 (Amendment No 3) Act (Loi rectificative de finances 2012, Law No ) and in the Finance Act 2013 (Loi de finances pour 2013, Law No ), most notably the 75% rate, which was to be imposed on a temporary basis for the tax years 2013 and More precisely, the measure involved imposing an 18% surcharge on that part of an individual s earned income in excess of EUR 1 million, on top of the 45% top rate of income tax. Taken together with social security contributions, the total rate of tax payable on that slice of earned income would have been 75%. Although the plaintiffs advanced several grounds for claiming that the measure was unconstitutional, the argument upheld by the Court concerned the incompatibility of the surcharge with the principle of joint household assessment. In France, income tax is mandatorily assessed on the basis of total household (foyer fiscal) income, against which family tax allowances (the quotient familial) are given, based on the number of family members etc. The proposed surcharge, on the other hand, was to be imposed by reference to the sole circumstances of the individual taxpayer, and was for this reason contrary to the constitution. The Court also upheld some of the plaintiffs objections against other measures, although the majority of measures against which the opposition complained were nevertheless held not to be contrary to the constitution. The Government has announced that it will come forward no later than September 2013 with revised proposals, but that it remains determined to require a greater contribution from those with the highest incomes. nmilbradt@soffal.fr New heavy-vehicle tax VAT rate on e-books A new tax on heavy goods vehicles is to be introduced as from 1 July 2013, subject to parliamentary approval. The tax will apply to lorries and other goods vehicles of 3.5 tonnes and above using roads other than motorways subject to toll charges. The tax will be levied according to region, traffic density, distance travelled and the characteristics of the vehicle. The European Commission has formally requested that France remove its reduced rate of VAT on e-books (see under European Union). ngroult@coffra.fr nmilbradt@soffal.fr 4

5 Germany Swiss tax agreement rejected The tax regularisation agreement negotiated by the German and Swiss governments is now effectively a dead letter following the failure of attempts to reach agreement on its ratification between the two Houses of the German parliament. Like the agreements signed with Switzerland by Austria and the United Kingdom, the Swiss-German agreement was designed to impose a one-off tax on undisclosed assets held in Switzerland by German nationals and to impose a withholding tax (the majority of which would be paid over to the German authorities) on income from assets remaining undisclosed to the German tax authorities. The agreement and the bill ratifying it had previously been passed by the Bundestag (the lower House of the German parliament) where Angela Merkel s centre-right coalition has a majority but rejected by the Bundesrat (the upper House) where opposition parties now have a majority. In such cases, the measure in dispute goes to the Vermittlungsausschuss (a mediation committee composed of members of both Houses) for a compromise to be sought. On the Swiss-German tax agreement, however, where the opposition sought more stringent measures, no compromise could be reached, and the committee s recommendation was accordingly that the agreement not be ratified. Without ratification, the agreement is inoperative. The Swiss government has announced that it is unwilling to renegotiate the terms of the agreement. The status quo therefore prevails. guido.karmann@moorestephens.de VAT: turnover method not only method for calculating deduction The European Court has upheld in principle the German authorities prescription of a method based on floor space rather than turnover when calculating the proportion of input VAT deductible on the construction of a mixed-use building (see under European Union). a.wischermann@rbs.de Ireland New local property tax The 2013 Budget presented to the Dáil (Parliament) by the Minister of Finance, Michael Noonan, on 5 December introduces a new local property tax among a series of other proposals, largely designed to raise revenue, although there are also some relieving measures. A brief summary of the more important measures follows: 5 Start-up companies having unused tax credits after their first three years of trading may carry them forward to future years. The maximum relief in any one year remains the amount of employer s PRSI (pay-related social security contributions). The amount of research & development (R&D) expenditure qualifying for R&D credits without reference to R&D expenditure in the 2003 base year is doubled to EUR Any excess expenditure qualifies only if it exceeds the amount spent in The life of the employment and investment incentive scheme (EIIS) has been extended beyond 2014 to The film tax relief scheme has also been extended to 2020, but will move

6 to a tax-credit basis in The surcharge on close companies retained investment and rental income will not now be levied where the retained income does not exceed EUR 2000 (previously EUR 635). The corporation tax rate remains 12.5% on trading income and 25% on non-trading income. The VAT standard rate remains 23%. The maximum turnover for taxable persons wishing to use the cashaccounting scheme is increased from EUR 1 million to EUR 1.25 million. Ireland will introduce a REIT (real-estate investment trust) régime. A new local property tax (LPT) applies from 1 July 2013 to all residential properties. The new tax replaces the household charge and the nonprincipal private residence charge. The rate of the new tax is 0.18% on the first EUR 1 million of value and 0.25% on any excess. Properties valued at EUR 1 million or less will be divided into market value bands, the first of which will be 0 to followed by bands of EUR , and the tax charge will be on the mid-point of that band. Accordingly, a property valued at EUR will fall into the band, on which the tax will be EUR x 0.18% = EUR 585 in a full year, but EUR in 2013 (half-year). The liability will be the owner s, but will fall on the occupier under a lease of over 20 years and in certain other circumstances. Social housing is not exempt except in special cases, and it will be the local authority or other housing provider who will normally be liable. Taxpayers are not required to assess the value of their own property. Revenue Ireland will send an estimated valuation with the first LPT return, to be sent in March 2013; only if they disagree with that valuation will taxpayers have to offer their own valuation. Once agreed, the value will remain fixed until 2017, even if improvements are carried out. mark.barrett@moorestephensnathans.com Jersey Amendments to Jersey Income Tax Law for 2013 The Minister for Treasury and Resources published his Draft Budget for 2013 on 17 October This was debated and approved by members of the States of Jersey (Parliament) on 4 and 5 December Among the items included in the Budget and now enacted as amendments to the Income Tax (Jersey) Law 1961, with effect from 1 January 2013 are the following: Exemption of certain income, profits or gains of a non-resident The Jersey Income Tax Law is amended to make it explicit that the exemption in respect of distributions made by a company to a person who is not resident in Jersey applies only to distributions made out of profits or gains charged on the company at the rate of 0%. Currently the Jersey Income Tax Law grants exemption to non-residents in respect of cash dividends and stock dividends by a company regarded as resident in Jersey except a company charged to tax under Schedule D at the standard rate or at the rate of 10%. Employer Income Tax Instalment Scheme (ITIS) Returns Changes are made relating to the duties of employers to deduct and account for tax. Employers are currently required to send to the Jersey Taxes Office information concerning each of their employees, including earnings. In practice, this information must be sent to the Jersey Taxes Office within 15 days of the end of each month. Under the ITIS provisions, the employer is, within the same deadline, required to remit to the Jersey Taxes Office the amount that the employer is required to deduct by way of tax in respect of those earnings. The amendments provide that if the required information is not sent, or it is not complete, or if the Jersey Taxes Office does not receive the correct amount of tax, the Office can estimate the amount required to be remitted and serve notice of that amount on the employer, requiring it to be paid by the date specified in the notice (which must be at least 15 days from the date of the notice). Life Assurance Premiums Tax relief is currently available for premiums paid with respect to life assurance policies taken out before 1 January Relief is capped at GBP 1000 per individual and is allowed as a deduction from an individual s assessable income in the tax year in which the premiums are paid. The relief is to be withdrawn with effect from the 2013 tax year. Additional Children s Allowance A taxpayer may currently claim an additional child allowance if either (a) he or she is not in receipt of a married person s allowance or (b) the taxpayer is in receipt of a married person s allowance but one of the spouses is totally incapacitated by physical or mental infirmity throughout the tax year. 6

7 The additional children s allowance is extended to civil partnerships effective from tax year A taxpayer will as a result be entitled to claim the children s allowance and the additional children s allowance if (a) he or she is not married or does not have a civil partner; or (b) the taxpayer has a spouse or civil partner whom the individual does not wholly maintain and who is not living with the taxpayer; or (c) the taxpayer has a spouse or civil partner either living with the taxpayer or, if not living with the taxpayer, is wholly maintained by the taxpayer and, in either case, one of the spouses or civil partners to the relationship is totally incapacitated by physical or mental infirmity throughout the tax year. Group Relief Provisions (Non-Financial Services Companies) The group-relief provisions are amended with effect from 1 January 2013 by inserting definitions of profits and loss or gains so that group relief does not apply to any profits or gains that would be chargeable under Schedule A (rents and other receipts in respect of land or property in Jersey). It is provided that losses arising from the trade carried on in Jersey of the disposal of land or any building or structure can only be offset against profits or gains arising from a similar trade. It is further enacted that losses arising from the trade carried on in Jersey of the exploitation of land (such as exploration, extraction or excavation) can only be offset against profits or gains arising from a similar trade. All the measures discussed have effect from the tax year 2012 unless otherwise specified. michael.goubert@moorestephens-jersey.com Luxembourg VAT rate on e-books The European Commission has formally requested that France remove its reduced rate of VAT on e-books (see under European Union). evelyn.guillaume@moore-stephens.lu Netherlands Court approves 150 km rule A court in the Netherlands has upheld the 150 km rule against a challenge under European law. A court in the Netherlands (Rechtbank Breda the Lower Court of Breda) has upheld the 150 km rule against a challenge under European law. The 150 km rule provides that individuals who have lived within 150 km of the Netherlands border for a period longer than 8 months in the last 24 before commencing employment in the Netherlands are not eligible to claim the 30% ruling for Netherlands tax purposes. The 30% ruling allows individuals coming to work in the Netherlands on a temporary basis to have 30% of their employment income paid free of Netherlands income tax, subject to certain conditions, of which the 150 km rule is one. The purpose behind the ruling is to compensate expatriate employees for the cost of expatriation. The taxpayer concerned was a German national who had lived within 150 km of the Netherlands-Germany border before being posted to Rotterdam. He challenged the application of the rule on the grounds that it constituted arbitrary discrimination 7

8 allegedly in breach of the Treaty on the Functioning of the European Union (TFEU), the European Convention on Human Rights and the International Covenant on Civil and Political Rights. The court held that the imposition of the 150 km rule was proportionate and necessary and thus not in breach of the TFEU freedoms. It observed that the taxpayer could still receive tax-free reimbursement of his actual moving costs. As to the civil rights aspect, the court considered that the inequality resulting from the rule was objective and reasonable, and hence not in breach of the Convention or Covenant. The case may go to appeal and, ultimately, may yet be referred to the European Court. Portugal New tax measures As part of its continued drive for fiscal consolidation, the Portuguese government has enacted new tax measures, generally taking effect from 30 October These include the following, of interest to non-residents in particular. The general rate of withholding tax on the investment income of non-residents has increased from 25% to 26.5%. It applies to: dividends; bank-deposit interest; income from debt securities, repo transactions and loan assignments; liquidation proceeds. Where investment income is paid to tax-privileged non-resident entities in a blacklisted jurisdiction, the withholding rate is now 35% (previously 30%). Capital gains derived from share disposals by individuals are now taxed at 26.5% (previously 25%). This rate applies to both resident and non-resident taxpayers. The 26.5% rate is scheduled to increase further to 28% in the draft legislation for the 2013 tax year. isabel.guerreiro@moorestephens.pt Romania Tax losses preserved after reorganisations Unrelieved tax losses belonging to companies ceasing to exist as a result of a merger or spin-off are now preserved and transferred to the newly created entities or to the entities that take over the assets of the absorbed or spun-off entity. This new rule is applicable for those mergers or spin-offs that produce effects starting from 1 October Previously, such tax losses ceased to exist together with the dissolved entity. The new rule is also applicable to mergers, spin-offs, transfers of assets and exchanges of shares concerning companies from two or more EU Member States. Accordingly, if the company that transfers assets/liabilities records tax losses, these tax losses will be transferred to the permanent establishment in Romania of the receiving company. The tax losses recorded by a European Company or European Cooperative Company in such situations are transferred to the permanent establishment in Romania of the European Company or European Cooperative Company. Changes to the VAT cashaccounting system Changes entering into effect from 1 January 2013 are being made to the VAT cash-accounting system. In Romania, VAT cash accounting is mandatory and not optional for those taxable persons meeting the relevant criteria. This concerns taxable persons: registered for VAT and whose main business activity is established in Romania and whose turnover recorded in the previous year did not exceed RON ; or who are newly registered and whose main business activity is established in Romania and who have applied for VAT registration during the current year. 8

9 Turnover for this purpose includes exempt supplies with the right of deduction ( zero-rated supplies) and supplies the place of which is deemed to be abroad. If eligible taxable persons do not themselves file the relevant application form for cash accounting, they will automatically be placed on it by the tax authorities. Likewise, taxable persons in the system who cease to be eligible will be withdrawn from it where they do not themselves file the relevant application. Taxable persons using cash accounting must: account for output VAT in the taxable period including the date on which their customer pays the invoice, but that date may be no later than 90 days after the issue date; deduct input VAT in the taxable period including the date on which they pay their supplier s invoice, regardless of whether or not the supplier applies cash accounting. Taxable persons not using cash accounting must: account for output VAT in the taxable period including the issue date of the invoice or according to the general rules for VAT accounting; deduct input VAT in the taxable period including the date on which they pay their supplier s invoice if the supplier applies cash accounting; deduct input VAT in the taxable period including the date on which their supplier s invoice is issued if the supplier does not apply cash accounting. Cash accounting is not available to persons whose main business activity is not established in Romania, even if they are registered for VAT purposes in Romania, nor to branches, fixed establishments or other non-resident companies. Taxable persons applying cash accounting must include the wording TVA la incasare (meaning VAT cash accounting ) on all their invoices. It is advisable for those persons not applying cash accounting to check whether their suppliers do so (in view of what is said above) by consulting the Registry of taxable persons who apply VAT cash accounting (Registrul persoanelor impozabile care aplica sistemul TVA la incasare), which should be available on the ANAF website (ANAF/Informatii publice/informatii privind agentii economice) as from January Currently, an interim version of the Registry is available. laura.stoica@auditone.ro Switzerland Lump-sum tax opponents secure referendum Campaigners against the elective lump-sum system of taxing wealthy foreigners living in Switzerland have secured enough signatures to their petition calling for a referendum on the issue at a federal level. important being that the individual derive no earned income in Switzerland. It may be some years before the issue is put to a vote, however. Under the lump-sum system, foreign individuals coming to live in Switzerland can opt to be subject to federal tax on their income and wealth not on their actual income and wealth but on a fixed multiple (now seven, for federal tax purposes) of their living expenses. Several conditions are attached, the most The lump-sum system is also available for cantonal and communal tax purposes, except in those cantons that have decided to withdraw the option. We reported in the last issue of European Tax Brief (Volume 2 Issue 3) that there are now five such cantons. 9

10 Tax agreement with Germany shelved The German Parliament has refused to ratify the agreement signed by Switzerland with Germany on the tax treatment of undeclared assets and income held or earned by German nationals in Switzerland. The Swiss Government has announced that it will not renegotiate the treaty; hence, there will be no change to the status quo. See under Germany. United Kingdom Mixed tax bag from Autumn Statement The Autumn Statement, in which the Chancellor of the Exchequer reviews the state of the Government s finances and looks forward to the annual Budget speech (to be given on 20 March 2013), was delivered on 5 December. The Chancellor sprang a surprise by announcing that the main rate of corporation tax would be further reduced to 21% from 1 April Currently 24%, it was scheduled to fall to 23% from 1 April 2013 and then to 22% on 1 April Another measure of tax relief was the tenfold increase (to GBP ) in the Annual Investment Allowance (AIA) for the two-year period beginning 1 January The AIA allows companies to write off investment in plant and machinery against tax in the year in which it is incurred. The Government had previously reduced the AIA from GBP to GBP with effect from 1 April On the personal tax side, the Government took a further step towards meeting its long-term objective of having a personal allowance (tax-free amount) of GBP by posting an above-inflation rise to GBP 9440 with effect from 6 April As previously announced, the top rate of income tax (on taxable incomes of GBP and more; currently 50%) will fall to 45% from 6 April 2013, and there will be modest increases in the tax-free amounts of capital gains and taxable transfers for inheritance tax. However, the Chancellor also announced that the maximum amount of pension savings qualifying for tax relief for an individual in any tax year is to reduce from GBP to GBP from 6 April 2014; the lifetime allowance will also decrease from GBP 1.5 million to GBP 1.25 million from the same date. Pension savings broadly means the total of employer s and employee contributions, but the position is rather more complicated for defined-benefit ( final salary ) schemes. As the recent controversy over corporate tax avoidance continues unabated, it was perhaps not surprising that there was a strong emphasis in the Statement on measures against avoidance and evasion. The Chancellor confirmed that a general anti-abuse rule will be introduced in the 2013 Finance Bill, and announced several targeted new anti-avoidance measures. Draft legislation for these and other previously announced measures due to appear in the 2013 Finance Bill was published on 11 December and further draft legislation has been published subequently. The Government is also to invest a further GBP 77 million in Her Majesty s Revenue and Customs (HMRC the tax authority) to increase revenues raised from tackling tax avoidance and evasion. 10

11 This investment is intended to allow HMRC to: accelerate the resolution of avoidance schemes, including long-standing avoidance schemes involving partnership losses; tackle offshore evasion and avoidance of inheritance tax using offshore trusts, bank accounts and other entities; expand its Affluent Unit, which deals with taxpayers with a net worth of more than GBP 1 million to help it work more effectively; and improve its risk technology to increase its capability to identify and tackle tax avoidance and evasion, and in particular to analyse risks posed in relation to large multinational companies and to increase its transfer-pricing specialist resources. reliefs on which the Government has been consulting since the March 2012 Budget, including: reliefs for companies involved in certain television production and video-game development; disincorporation relief, providing for tax-free transfers from the company being dissolved to its shareholders; increasing the GBP cap for the purposes of inheritance tax on tax-free transfers of assets to non-uk domiciled spouses to the amount of the nil-rate band, currently GBP ; and allowing small businesses to opt to calculate their taxable profits on a cash basis. jacquelyn.kimber@moorestephens.com The Government will also amend HMRC s data-gathering powers to allow it to issue notices to merchant acquirers, who purchase payment-card transactions, to identify those who are not declaring their full tax liability. The draft Finance Bill material also contains a number of new tax Currency table For ease of comparison, we reproduce below exchange rates against the euro and the US dollar of the various currencies mentioned in this newsletter. The rates are quoted as at 17 January 2013, and are for illustrative purposes only. Currency Equivalent in euros (EUR) Equivalent in US dollars (USD) Euro (EUR) Pound sterling (GBP) Romanian leu (RON) Up-to-the-minute exchange rates can be obtained from a variety of free internet sources (e.g. converter). For more information please visit: We believe the information contained in European Tax Brief to be correct at the time of going to press, but we cannot accept any responsibility for any loss occasioned to any person as a result of action or refraining from action as a result of any item herein. Published by Moore Stephens Europe Ltd (MSEL), a member firm of Moore Stephens International Ltd (MSIL). MSEL is a company incorporated in accordance with the laws of England and provides no audit or other professional services to clients. Such services are provided solely by member firms of MSEL in their respective geographic areas. MSEL and its member firms are legally distinct and separate entities owned and managed in each location. DPS21520 January 2013