This publication gives an overview of key international tax developments across the Linklaters network. Please click here to read the publication. (10 page PDF).

 
Topics include:
 

International Developments
 

  • Global tax reform – G20 Finance Ministers reach historic agreement on new international tax framework
     

EU Developments
 

  • EU Green Deal – “Fit for 55” Package published
     

Belgium
 

  • Proportionality principle limits the offsetting of disputed tax receivables against tax payables 
     

France
 

  • Administrative Supreme Court – Three significant decisions relating to the taxation of management package/employee incentive 
     

Germany
 

  • ATAD Implementation Act, Tax Haven Prevention Act and Act to Modernise the Corporate Income Tax Law promulgated

  • The Federal Ministry of Finance on the tax treatment of “cum/cum transactions”

  • Remuneration for the temporary transfer of rights entered in a domestic public book or register
     

Netherlands
 

  • Interest deduction limitation – Hunkemöller case
     

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.
 

 

For further information, please contact:

 

Dick Hofland, Partner, Linklaters

dick.hofland@linklaters.com