International Tax Round-up - March 2020

This publication gives an overview of key international tax developments across the Linklaters network. Please click here to read the publication.
 
Topics include:

Covid-19 – Current tax developments

International Developments
  • OECD transfer pricing guidance for financial transactions
  • OECD analysis of effect of “BEPS 2.0” shows increased tax revenue
EU Developments
  • CJEU finds cross-border relief not available to company which moved tax residence
  • EU action plan to fight tax evasion
France
  • Covid-19 – Tax measures
  • Abuse of law; management package
Germany
  • Covid-19 – Tax measures
  • DAC6 – Federal Ministry of Finance releases draft administrative circular
  • Cum/ex – Decision in the first criminal proceeding on cum/ex transactions
Italy
  • Covid-19 – Tax measures
Luxembourg
  • Covid-19 – Tax measures
  • Law of 25 March 2020 implementing DAC 6 published
Netherlands
  • Covid-19 – Tax measures
Poland
  • Covid-19 – Tax measures
Portugal
  • Covid-19 – Tax measures
  • Portugal deposits ratification instrument for MLI
Spain
  • Covid-19 – Tax measures
Sweden
  • Covid-19 – Tax Measures
  • Legislative changes – Chemical tax for foreign traders; Amendment of tax treaty between Sweden and Switzerland
  • Supreme Administrative Court – et al. Swedish participation exemption apply to shares in a Liechtenstein Anstalt
  • The Council of Advance Tax Rulings – et al. No essential connection to Sweden for holdings through a Jersey fund
United Kingdom
  • Covid-19 – Tax measures
  • UK Budget 2020: Key measures for large business
  • UK Finance Bill published
United States
  • Covid-19 – Tax measures
  • Should there be questions or in case you are interested to further discuss any of the developments, please do not hesitate to contact your local Linklaters tax team.