International Tax Round-up - November 2020

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 invites comments on proposals to strengthen MAP process
EU Developments
  • DAC8 – Proposal for an expansion of the EU Mutual Assistance Directive to include an exchange of information in the context of crypto currencies
  • CJEU finds that actual use takes precedence over intended use for VAT recovery 
  • Significant transfer pricing case – Commissioner of Taxation v Glencore Investment Pty Ltd
  • Negotiation of first memorandum of understanding dealing with international tax arbitration
  • Stamp duty reforms
  • Non-resident capital gain taxation on disposal of substantial shareholdings
  • Limited tax liability on the transfer of rights entered in domestic registers
  • Fund Location Act – draft bill
  • Multilateral Instrument (MLI) – contract act for the ratification published
  • Interest deduction limitations – Hans Anders case
  • DAC6 – Deadline extension
  • Legislative Changes – Proposed expanded scope for qualified employee stock options
  • The Supreme Administrative Court – i.a. Calculation of the basis for tax surcharges
  • The Council for Advance Tax Rulings – i.a. Swedish tax consolidation and the Swedish Tax Evasion Act
  • The Swedish Tax Agency – i.a. Indirect holdings according to DAC6

United Kingdom

  • Further draft legislation published for Finance Bill 2021 alongside consultation responses
  • Office of Tax Simplification makes far-reaching recommendations in relation to capital gains tax

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.