International Tax Round-up - October 2021

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


Topics include:

International Developments
  • Global tax reform – G20 Finance Ministers support final agreement on key components of Pillar One and Pillar Two; agreement struck on treatment of DSTs in Western Europe
EU Developments
  • Public country-by-country reporting – Council adoption
  • Revised list of non-cooperative jurisdictions for tax purposes (“EU blacklist”)
  • New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes
  • Option model for corporate income tax treatment of partnerships
  • Constitutionality of interest on additional tax claims and tax refunds – administrative circular following the BVerfG decision
  • Italy
  • Clarifications on the favourable tax regime for inbound workers transferring their tax residence to Italy (Impatriati Regime)
  • Dry income upon conversion of carried interest participating financial securities (“Carried Interest SFPs”) into ordinary shares
  • Luxembourg
  • Draft Budget 2022 Law
  • Implications of revised EU list of non-cooperative jurisdictions
  • Netherlands
  • Corporate income tax rate set to rise from 25.0% to 25.8%
  • Tightening of earnings stripping rule
  • Portugal
  • Draft State Budget Law for 2022
  • United Kingdom
  • Transition from digital services tax to Pillar One

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.