International Tax Round-up - April 2021

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

International Developments
  • Taxation of the digital economy – Biden Administration offers new compromise proposal to the OECD Inclusive Framework
  • OECD proposes changes to commentary on Article 9 (transactions between associated companies) of the Model Tax Convention
France
  • Beneficial ownership – Performing Rights Society Ltd (PRS) case law 
Germany
  • Real estate transfer tax reform – Implementation of share deal reform as of 1 July 2021
  • DAC6 administrative circular published
  • Federal Parliament adopts Fund Location Act
Luxembourg
  • Extension of - and guidance on - tax abatement for waived rental income
Netherlands
  • Public consultation legislative proposal to subject reverse hybrid entities to tax
  • Public consultation legislative proposal to counter hybrid mismatches resulting from the Dutch classification of legal entities
Portugal
  • Amendments to the Tax Benefits Code
Sweden
  • The Court of Justice of the European Union – Establishment according to the EU VAT directive
  • The Council for Advance Tax Rulings – Shares held for business purposes; Taxation of alternative funds
United Kingdom
  • Reverse charge applies to overseas services received by UK taxable person for non-economic business activities
  • Tax consultations and calls for evidence published on “tax day”

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.