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
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.