International Tax Round-up - January 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 Tax Developments
  • OECD’s Digital Tax Project technically nearing completion
  • Covid-19: OECD transfer pricing guidance
  • Year in Review, Year to Come
EU Developments
  • EU Commission prepares draft EU digital tax
Australia
  • Commissioner ruling on targeted integrity measure contained in Australian hybrid mismatch rules
  • Board of Taxation releases Consultation Paper into its Review of CGT Roll-overs
Belgium
  • Tax on securities accounts revised
France
  • Selected main new features of the 2021 Finance Act
Germany
  • Protocol of Amendment to the DTT Germany/United Kingdom
  • Disclosure rules for international relations
  • Extension of the retroactive periods
Italy
  • New Italian tax exemptions for dividends and capital gains derived by EU/EEA investment funds
Luxembourg
  • Tax authorities issue Circular on interest limitation rules
Netherlands
  • The State Secretary for Finance’s Sofina Decree
  • Conditional interest withholding tax
  • Revised substance requirements for financial service companies (FSCs)
Portugal
  • The Portuguese State Budget Law for 2021
  • New measures due to the Covid-19 pandemic
  • WHT reimbursement for EU Funds investing in Portugal / “Fokus Bank” Claims – recent developments
  • Brexit
Sweden
  • Court of Justice of the European Union – Swedish rules are contrary to the freedom of establishment
  • The Supreme Administrative Court – Investors in a fund considered the lenders to a company
United Kingdom
  • DAC6: Significant reduction in scope of rules in UK

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.