EU: Tax Policy Plans for 2022

December 08, 2021

At a meeting of the EU Parliament’s FISC subcommittee on 30 November 2021, the EU Commissioner responsible for economic and tax issues outlined the European Commission’s tax plans for 2022 and was questioned on the plans by members of the

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Luxembourg issues Draft Law on the deduction of interest and royalties expenses

April 08, 2020

On 30 March 2020, the Luxembourg government has presented a Draft Law N°7547 to the Parliament introducing a non-deductibility of interest or royalties paid to associate enterprises established in countries that are “blacklisted” as being

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Italy publishes Law 117 to implement EU Directives

October 28, 2019

On 4 October 2019, Italy has published Law No. 117 in the Official Gazette, approving the legislative decrees for the implementation of several EU Directives. The Directives will be consulted on by parliament but do not require further approval

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Belgium approves draft law to transpose EU directive on cross-border arrangements

October 15, 2019

On 11 October 2019, the Belgian Council of Ministers approved a draft law to transpose EU Directive 2018-822 of 25 May 2018 on reportable cross-border tax planning arrangements. The Directive includes measures to require the reporting of

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Ecuador: NA Approves Mutual Assistance Agreement on Tax matters

September 04, 2019

On 7 August 2019, Ecuador's National Assembly approved the bill for the ratification of the OECD-Council of Europe Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 protocol. Its objective is to facilitate

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Belgium: Constitutional Court announces the fairness tax unconstitutional

March 11, 2018

On 1 March 2018, The Constitutional Court of Belgium announced the fairness tax unconstitutional, thus nullifying it (judgment n° 24/2018). According to the Court’s ruling, however, the fairness tax is maintained until financial year 2017 (tax

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Poland: MoF publishes a statement regarding exemption for dividends

November 28, 2017

The Polish Ministry of Finance (the MoF) released a statement that identified cases of abuse of tax exemption for dividends by making their payments using intermediaries on 3rd November 2017. As of 1 January 2016, the Polish dividend withholding tax

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EU follows OECD with digital tax consultation

November 09, 2017

On 26 October 2017, the European Commission published a public consultation on digital taxation.  This follows on from the Commission’s September Communication setting out its vision for the need to address digital taxation and some possible

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UK offshore finance companies possibly illegal under EU law

November 09, 2017

The European Commission announced on 26 October that it has initiated proceedings against the UK on the grounds that its CFC rules may infringe EU State Aid law. The Commission’s challenge focuses on the fact that certain offshore group financing

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European Commission calls for more flexible rule making

November 09, 2017

In its work programme for 2018, published on 24 October 2017, the European Commission  has expressed support for moving from unanimity to qualified majority voting by EU Member States on certain EU legislation, including tax legislation. The

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EU takes action against Amazon and Apple in tax cases

November 09, 2017

The European Commission issued a statement on 4 October 2017 to the effect that it had ordered Amazon to repay EUR 250 million plus interest that it claims Amazon should have paid in taxes on European sales made by the group through its Luxembourg

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Belgium: Netherlands UCITS under EU Parent-Subsidiary Directive, Dividend withholding tax exemption

March 13, 2017

The EU Court of Justice issued a judgment in a case regarding application of the EU Parent-Subsidiary Directive, and specifically a withholding tax imposed by Belgium on dividends paid by a subsidiary company of Belgium to its Dutch parent companies

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Cyprus: Tax department issues guidance relating to exchange of information with Austria

February 07, 2017

Recently the Cyprus tax department issued a guidance which is related to the exchange of information with Austria under Directive 2014/107/EU on mandatory automatic exchange of information along with Common Reporting Standard (“CRS”) based

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Andorra deposits instrument of ratification for amending protocol to savings agreement with EU

December 23, 2016

On 20 December 2016, Andorra deposited its instrument of ratification for the amending protocol to the EU Savings Directive Agreement that was signed on 12 February 2016, concluding the legal requirements for its entry into force. The amending

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Belgium: New changes in anti-hybrid and anti-abuse rule

December 20, 2016

According to official gazette published on 8 December 2016, in Belgium, legislation implementing changes to the “Parent-Subsidiary directive” and introducing a spread or installment payment regime relating to the exit tax liability. The law

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France-Approved Finance Bill 2016 and amended Finance Bill 2015

December 24, 2015

The French Parliament approved the Finance Bill for 2016 and and the amended Finance Bill for 2015 on 17 December 2015. The Finance Bill enacts the country-by-country (CbC) reporting requirement into the legislation of France. From 1 January 2016

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Israel signs convention and protocol in tax matters

November 25, 2015

Israel joined the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on 24th November 2015. The Convention came into existence  on 25th January 1988 and the amending protocol was signed on 27th May

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Luxembourg: Proposed Corporate Tax Changes For 2015-2016

September 01, 2015

Recent amendments was made to the EU Parent-Subsidiary Directive into Luxembourg tax law and published on 5 August 2015. It has already been submitted to the Luxembourg Parliament. The measures include the provisions to modify the domestic

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