International Taxation

Malta’s Commissioner for Revenue has published Guidelines on the reduced VAT rate applicable to the hiring of pleasure boats. In terms of the Value Added Tax Act (Amendment of Eighth Schedule) Regulations 2023, extended the scope of the reduced VAT rate of 12% rate on the hiring of pleasure boats, among other things, with effect […]

The European Union’s (EU’s) proposed ‘unshell’ directive, also referred to as ATAD 3, is looking more likely not to be adopted in its current updated from in the face of opposition from some Member States. The draft directive was published in December 2021 as a means of deterring the use of shell companies to avoid […]

On 18 October 2023, Malta’s Tax and Customs Commissioner issued a Guidance Note on Recognized Stock Exchanges. The guidance note now lists the UK stock exchanges that are recognized by the Maltese Tax & Customs Administration for the purposes of the Income Tax Acts and the Duty on Documents and Transfers Act, which include the following […]

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 […]