International Tax Round-up - September 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 – Pillar One / Pillar Two

Belgium

• Tax consequences of volume ownership

Germany

• Cum/ex – Ruling of the Federal Court of Justice of 28 July 2021
• Constitutionality of interest on additional tax claims and tax refunds

Italy

• Tax ruling on the (un)availability of certain tax benefits for real estate refurbishment works to a ReoCo under the Italian Securitisation Law
• The separation of activities for VAT purposes is available in case of objectively autonomous activities carried out by the same legal entity to allow an efficient creditability of input VAT
• Supreme Court decision regarding a tax assessment concerning the alleged Italian tax residence of a Luxembourg company

Luxembourg

• Extension of agreements with neighbouring countries clarifying tax treatment of cross-border workers in the context of the Covid-19 crisis
• Luxembourg tax authorities clarify tax treatment of persons running a photovoltaic installation

Netherlands

• Dutch tax plan package 2022

Portugal

• CJEU case law – taxation of foreign listed shares’ dividends

United Kingdom

• UK Autumn Budget date announced as 27 October 2021
• New health and social care levy announced
• Competent authority agreements on interpretation of LOB article in UK/US tax treaty