International Taxation

The OECD has published administrative guidance to address several issues arising under a new global minimum tax framework, including the treatment of the U.S. global intangible low-taxed income regime under the rules. The February 2 guidance responds to 27 concerns about the framework from countries involved in developing a two-pillar plan to modernize the global […]

The Court of Justice of the European Union (“CJEU“) has just recently re-confirmed in its judgment dated 8 December 2022 (case C-694/20, Orde van Vlaamse Balies) the fundamental principle of professional secrecy for lawyers, tax advisors and accountants. In this case, the Belgian Constitutional Court referred a question to the CJEU for a preliminary ruling in […]

On 8 November 2022 the Court of Justice of the European Union (CJEU) delivered a significant blow to the European Commission in the Fiat / Luxembourg State aid case . The decision is likely to have wide-reaching ramifications for other State aid cases which are currently under appeal and other ongoing investigations which have been initiated […]

Further to the consultation completed earlier this year (see MIT News 21 December 2021), the Transfer Pricing Rules 2022 have been published by Legal Notice 284 of 2022. More detailed information can be found in our publication, linked here.  

He was asked why he did not do anything about the UK’s non-dom tax status in yesterday’s Autumn Statement. The chancellor said the Treasury did not give him estimates on how much abolishing the non-dom tax status would raise and added that he would prefer the super rich “stayed here and spent their money here”. […]

Widespread speculation that non-dom tax breaks are under active review by the UK’s Treasury department was picked up in a LinkedIn post by leading tax and trusts lawyer James Quarmby, head of Stephenson Harwood’s private wealth team. He commented: “I predicted a week ago, the conservative government is now reviewing the non dom rules. Our […]

Hong Kong’s government has gazetted the most significant change in its tax laws in over four decades, imposing profits tax on multinational enterprises’ foreign-sourced income that is currently exempt. The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 is in response to pressure from the European Union, which has concerns that multinational enterprises (MNEs) can […]

The European Commission has approved Malta’s recovery and resilience plan, which includes measures to curb aggressive tax planning practices. As provided in the annex to the Proposal for a Council Implementing Decision on the approval, the measures include the following: Reform C6-R9: Aggressive Tax Planning (ATP) – Code of Conduct Group The objective of this […]

The European Parliament issued a release on 20 May 2021 announcing the approval of a program to help tax authorities fight tax evasion. Parliament greenlights EUR 270 million programme to help tax authorities fight tax dodging MEPs approved the regulation establishing the Fiscalis programme running from 2021-2027, which will provide financial resources to national tax […]

On 12 May 2021, the General Court of the European Union issued a judgment annulling the European Commission’s 2017 decision that Luxembourg granted illegal State aid (a selective advantage) to Amazon that had amounted to around EUR 250 million. The decision was the result of an investigation launched in 2014 into a tax ruling provided […]