The UK and Luxembourg Signed A New Double Tax Treaty
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. ... - Continue reading
Category: OECD
What is the global minimum corporate tax?
The global minimum corporate tax on MNCs was aimed at discouraging them from shifting profits to low-tax countries. But it will reduce the incentives to attract investment in developing countries ... - Continue reading
The Pillar Two model rules: a train wreck in the making
On December 20, 2021, the OECD issued model rules for Pillar Two—the 15% global minimum tax. It is a brutally complex 70-page package and introduces two fundamental changes to the October 2021 OECD framework: a new Qualified Domestic Minimum Top-Up tax (QDMTT) and a significant rewrite of the Undertaxed Payment Rule (UTPR). ... - Continue reading
Q&A: tax issues for private equity funds in Cayman Islands
Under current Cayman Islands law, there are no Cayman Islands taxes on income or gains of the private equity fund (PE fund) or on gains on dispositions of shares or partnership interests, and distributions made by a PE fund will not be subject to withholding tax in the Cayman Islands. ... - Continue reading
Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract
In recent years, the Spanish tax administration and Spanish courts have had a clear tendency to challenge the provision of intragroup services, denying its corporate income tax deductibility and increasing the tax burden for taxpayers carrying out these transactions in Spain. ... - Continue reading
Austria updates transfer pricing guidelines
An update on Austrian transfer pricing rules was made on the 7th October 2021. Details are here. ... - Continue reading
Frydenberg welcomes historic OECD tax agreement
More than 130 countries agreed on Friday to rolling out historic changes to international tax rules, after leaders agreed to a new global minimum tax rate of 15 per cent targeted at companies with annual revenue of more than 750 million euros. ... - Continue reading
European Union: EUTA Special Edition: EU Responses To COVID-19 (Coronavirus) Crisis
The COVID-19 (Coronavirus) pandemic is affecting hundreds of thousands of people and is leading, all over the world, to far-reaching health and safety measures. As a result, the COVID-19 crisis has major social and economic consequences. Measures are being adopted to limit the impact on taxpayers as much as possible. ... - Continue reading
