International Taxation

The European Union announced today it has removed Barbados from its blacklist of countries it deems non-cooperative in matters of taxation, and added Dominica. The EU’s review of Barbados’ status comes just four months after the bloc’s finance ministers voted to blacklist the Caribbean island. Blacklisted jurisdictions face higher scrutiny, loss of access to EU […]

The Constitutional Court of Belgium has requested a preliminary ruling from the Court of Justice of the EU (CJEU) about exceptions to reporting tax arrangements under the EU Council’s Directive 2018/822 (DAC6). The Constitutional Court of Belgium has requested a preliminary ruling from the Court of Justice On February 19, The Belgium high court, Grondwettelijk […]

On the 1st of December 2020, Poland and Malta have signed a protocol amending the 1994 income tax treaty. According to the Polish Ministry of Finance, the protocol provides for the implementation of the minimum BEPS standards and, in particular, includes amendments providing for Withholding tax on fees for technical services; Specifically, changes to the […]

Malta’s Commissioner for Revenue has announced that the DAC6 XML Schema to be used for filing information in relation to reportable cross-border arrangements and the DAC6 XML Schema user guide are now available on the following on their website Reportable Cross-Border Arrangements On 25 May 2018 Council Directive 2011/16/EU (‘Directive on Administrative Cooperation’) was amended […]

On 17 December 2019 Legal Notice 342 introduced regulations implementing the European Union Directive on the mandatory disclosure and exchange of cross-border tax arrangements were published (commonly referred to as DAC6). The regulations had to come into force as from 1 July 2020, however their enactment was postponed due to pandemic. The new effective date […]

On 1 October 2020, Malta and Russia signed a Protocol amending the Convention for the Avoidance of Double Taxation and the prevention of Fiscal Evasion between the two countries. This new Protocol includes amendments to Article 10 of the Convention concerning dividends payments, Article 11 concerning interest payments as well as Article 24 being the Non-Discrimination […]

The British Virgin Islands government has officially announced its commitment to the implementation of public registers of beneficial ownership in the territory, despite “reservations”. Premier Andrew Fahie said: “Your government commits to working in collaboration with Her Majesty’s Government towards a publicly accessible register of beneficial ownership for companies, in line with international standards and […]

On 8 September 2020, the Republic of Cyprus and the Russian Federation signed the Protocol to amend the double tax treaty between the two countries. The amendments to the Treaty should be effective as of 1 January 2021 (provided the Protocol is ratified by both parties by the end of 2020). We hereby list the most […]

Russia has announced it is unilaterally cancelling its double taxation agreement (DTA) with Cyprus, following the failure of negotiations to amend the treaty in line with Moscow’s new anti-offshoring business tax regime. In April 2020, President Vladimir Putin announced a new 15 per cent tax on dividend payments from Russian businesses to parent companies in […]

Introduction In a landmark ruling, the General Court of the European Union has annulled the 2016 adoption of a decision taken by the Commission regarding Irish tax rulings granted in favour of Apple. The Court concluded that the Commission failed to prove, to the requisite legal standard, that the tax rulings granted by the Irish […]