International Tax Round-Up – March 2021.

22 April 2021
 

This publication gives an overview of key international tax developments across the Linklaters network. Please click here to read the publication.
 
Topics include:
 

EU Developments
 

• Amendment to the Mutual Assistance Directive (DAC7) published

• Updated EU list of non-cooperative jurisdictions for tax purposes

• Limited tax credit for overseas withholding not precluded by EU law

• CJEU applies “reverse Skandia” to VAT group incorporating principal establishment but not branch
   

Australia
 

• Negotiation of first memorandum of understanding dealing with MLI arbitration – Australia-Belgium MOU
   

France
 

• Permanent establishment, OECD guidelines – Conversant case law
   

Germany
 

• Government adopts ATAD Implementation and Amendments to Corporate Income Tax Law

• Limited tax liability on the transfer of rights entered in domestic register

• Third Corona Tax Relief Act published
   

Italy
 

• First ruling on the tax treatment applicable to Italian real estate securitisation vehicles
   

Netherlands
 

• Legislative proposal to counter transfer pricing mismatches
   

Sweden
 

• Legislative changes – Hybrid mismatch arrangements; Termination of tax treaties (Sweden-Greece and Sweden-Portugal)

• The Supreme Administrative Court – Scrapping and deduction; Swedish rules are contrary to the freedom of establishment

• The Council for Advance Tax Rulings – Sale and distribution from foreign estate
   

United Kingdom
 

• Budget 2021

• Finance Bill 2021 published
   

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.