International Tax Round-up - November 2021

This publication gives an overview of key international tax developments across the Linklaters network.

 

Topics include:

International Developments
  • Global tax reform – G20 Leaders confirm final agreement on Pillar One and Pillar Two
EU Developments
  • Public country-by-country reporting – adoption by EU Parliament
  • Belgium
  • Case law: share deal on project company or project development services?
Germany
  • Coalition agreement of the new Federal Government
  • Federal Court of Finance on a limited tax liability for interest income from convertible bonds
  • Option model for corporate income tax treatment of partnerships – administrative circular
Italy
  • VAT regime of transactions between a UK parent company, part of a UK VAT group, and its Italian branch
  • Capital gain income tax regime of an earn-out
     
Netherlands
  • Legislative proposal to revise stock option tax regime on hold
Portugal
  • Madeira Free (Trade) Zone – up to EUR 1b State Aid decision to be enforced against 300 companies
United Kingdom
  •   Autumn Budget 2021
  • Finance Bill 2022 and Tax Administration and Maintenance Day
     

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.