International Tax Round-up - September 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
  • Global tax reform – Pillar One / Pillar Two
Belgium
  • Tax consequences of volume ownership
Germany
  • Cum/ex – Ruling of the Federal Court of Justice of 28 July 2021
  • Constitutionality of interest on additional tax claims and tax refunds
Italy
  • Tax ruling on the (un)availability of certain tax benefits for real estate refurbishment works to a ReoCo under the Italian Securitisation Law
  • The separation of activities for VAT purposes is available in case of objectively autonomous activities carried out by the same legal entity to allow an efficient creditability of input VAT
  • Supreme Court decision regarding a tax assessment concerning the alleged Italian tax residence of a Luxembourg company
Luxembourg
  • Extension of agreements with neighbouring countries clarifying tax treatment of cross-border workers in the context of the Covid-19 crisis
  • Luxembourg tax authorities clarify tax treatment of persons running a photovoltaic installation
Netherlands
  • Dutch tax plan package 2022
Portugal
  • CJEU case law – taxation of foreign listed shares’ dividends
United Kingdom
  • UK Autumn Budget date announced as 27 October 2021
  • New health and social care levy announced
  • Competent authority agreements on interpretation of LOB article in UK/US tax treaty
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.