The measures will include withholding taxes on, or non-deductibility of, outbound payments. Dividends are already non-deductible, so the appropriate measure will be a withholding tax. The tax will also apply to royalties and dividends, with associated changes to the underlying charge to Irish tax on recipients in jurisdictions listed by the EU as non-cooperative, low-tax […]

The Court of Justice of the EU (CJEU) clarified the concept of a fixed establishment (FE) for VAT purposes in its recent decision in the case C-232/22 (Cabot Plastics Belgium SA). The CJEU held that a toll manufacturer in Belgium acting under an exclusive contract did not constitute an FE for its affiliated Swiss principal. […]

The Residency Malta Agency together with Malta Enterprise has recently launched The Malta Start-up Residence Programme, which grants its beneficiaries a three-year residence permit renewable for a further 5 years, as well as eligibility for long-term residency in Malta. The programme is designed to boost Malta’s competitiveness and attract innovative start-ups and qualified entrepreneurs to […]

As empowered by Article 98(2) of the Income Tax Act, the Commissioner For Revenue has, on 31 August 2020, published a set of guidelines (the Guidelines) concerning the scope, interpretation and application of the Anti-Tax Avoidance Directives (ATAD) Implementation Regulations (S.L.123.187.) with particular reference to the Interest Deduction Limitation rules, Exit Taxation, Controlled Foreign Company […]