International Tax Round-up - May 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
  • OECD opinion on interpretation and implementation of the MLI
EU Developments
  • EU Commission announces an ambitious package of measures for “Business Taxation for the 21st century”
  • State aid or acceptable arm’s length taxation of the digital economy? – General Court of the European Union annuls the decision of the European Commission against Amazon
  • Roaming services correctly subject to VAT under use and enjoyment rules
  • Federal Budget 2021-2022
  • EU judges oblige tax authorities to apply anti-abuse provisions
  • ATAD Implementation Act adopted
  • Act to Modernise the Corporate Income Tax Law adopted
  • Withholding Tax Relief Modernisation Act adopted
  • Reformed real estate transfer tax regime enters into force on 1 July 2021
  • New tax exemption for dividends derived by EU/EEA investment funds: first clarifications issued by the Italian tax authorities
  • Legislative proposal dividend withholding tax regarding distributions to low-tax jurisdictions and in situations of abuse
United Kingdom
  • Call for evidence on simplifying the VAT rules applicable to land
  • Tribunal allows unilateral credit for US tax when treaty did not apply  

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.