International Tax Round-up - July 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 – G20 Finance Ministers reach historic agreement on new international tax framework
EU Developments
  • EU Green Deal – “Fit for 55” Package published
  • Proportionality principle limits the offsetting of disputed tax receivables against tax payables 
  • Administrative Supreme Court – Three significant decisions relating to the taxation of management package/employee incentive 
  • ATAD Implementation Act, Tax Haven Prevention Act and Act to Modernise the Corporate Income Tax Law promulgated
  • The Federal Ministry of Finance on the tax treatment of “cum/cum transactions”
  • Remuneration for the temporary transfer of rights entered in a domestic public book or register
  • Interest deduction limitation – Hunkemöller case

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.