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European Union › International Tax Issues

The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of... more +
The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -
Carey Olsen

Guernsey funds – special considerations for US managers

Carey Olsen on

Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

BakerHostetler

Analysis of International Tax Changes Under the 2025 Tax Legislation

BakerHostetler on

The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more

DLA Piper

New VAT Guidelines on Company Vehicles for Employees

DLA Piper on

The French tax authorities have issued new guidelines on the VAT treatment of company cars provided to employees. When a vehicle is provided for a defined consideration, it is considered a taxable service. This includes...more

DLA Piper

Dutch Suppliers – Enhanced Checks on VAT Status of Customers Recommended

DLA Piper on

When the Dutch entrepreneur receives a purchase order from a customer, they order the same product from a non-EU established merchant (Merchant) via an online platform operated by a non-EU entrepreneur (Platform operator)....more

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

Goodwin on

The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

Mayer Brown

La différence de traitement des quotes-parts de frais et charges selon la localisation des filiales conforme à la CEDH

Mayer Brown on

La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Eversheds Sutherland (US) LLP on

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

Hogan Lovells

The Italian VAT reform on personnel secondment

Hogan Lovells on

On 18 February 2025, the Italian Revenue Agency issued Ruling n. 38/2025 (the "Ruling"), commenting the enactment of the Decree-Law No. 131 of 16 September 2024 ("Decreto salva infrazioni" – converted into Law No. 166 of 14...more

DLA Piper

Belgium - VAT: New Belgian Circular Letter on the VAT Implications of Credit Insurance - Monthly Indirect Tax Alert – January 2025

DLA Piper on

Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more

DLA Piper

Germany VAT - VAT Grouping: Final Verdict of the German Federal Fiscal Court in Finanzamt - Monthly Indirect Tax Alert – January...

DLA Piper on

The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more

A&O Shearman

Overview of the New Luxembourg Tax Measures to Improve Talent Attraction and Retention

A&O Shearman on

On December 20, 2024, the Luxembourg parliament adopted without material changes the tax relief package bill that we covered in a previous publication. Amongst others, this law introduces, as of fiscal year 2025, the...more

A&O Shearman

What Does 2025 Hold for the Global Minimum Tax (Pillar Two)?

A&O Shearman on

Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more

Hogan Lovells

Draft Commission Notice regarding EU Taxonomy delegated acts published

Hogan Lovells on

The European Commission has published a Draft Commission Notice in respect of the delegated acts to the EU Taxonomy. These are intended to clarify particular technical screening criteria in relation to (i) economic...more

McDermott Will & Emery

Exit tax for investement shares

McDermott Will & Emery on

Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Your Homework Will Be Graded: The ECJ’s Apple Decision and Its Implications for International Tax

Skadden, Arps, Slate, Meagher & Flom LLP on

On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a...more

Morgan Lewis

'FASTER" EU Council of Ministers Adopts Directive to Harmonize Withholding Tax Procedures

Morgan Lewis on

On May 14, 2024, ECOFIN agreed on the Directive on Faster and Safer Relief of Excess Withholding Taxes (so-called FASTER Directive) after numerous adjustments to the EU Commission's proposal for a directive from June last...more

Conyers

Economic Substance Regime Overview

Conyers on

The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Mayer Brown

Europe Daily News, 19 March 2024

Mayer Brown on

COMPETITION - Non-opposition to a notified concentration (Case M.11409 - Elia / Glentra / Energyre / Energyre Giga Projects USA) - Non-opposition to a notified concentration (Case M.11475 - Mitsui / Osaka Gas / RWE KK /...more

A&O Shearman

Amount B or not to be? The OECD’s Pillar One Amount B report

A&O Shearman on

The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

Conyers

Guiding Captives Through Global Developments

Conyers on

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

Conyers

British Virgin Islands Removed from EU Tax Blacklist

Conyers on

Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

BCLP

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

Holland & Knight LLP on

More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Morgan Lewis

Draft Minimum Tax Directive Implementation Act: Minimum Taxation and Other Relevant Measures Legal Insights Germany

Morgan Lewis on

On August 16, 2023, the German federal cabinet approved the government draft bill to implement Council Directive (EU) 2022/2523 to ensure global minimum taxation and further accompanying measures (Minimum Tax Directive...more

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