European Tax Law
EU tax law and case law from the Court of Justice of the EU strongly influence tax law in EU Member States. Organisations operating in Europe must keep well-informed of EU tax law and state aid developments, especially as European Commission investigations increase. Our expert team closely monitors developments and keeps you informed of any that will affect your business.
News
Implementing Pillar One & Pillar Two
To adapt international tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework proposes a two-pillar overhaul of the existing system as from 2023/2024. Tax directors and their teams can already model the impact and assess opportunities for manageable restructurings to mitigate the increased complexity.
12-05-2022
During the 8th Annual International Tax Developments Seminar, several Loyens & Loeff tax experts as well as officials from the Dutch Tax Authorities updated the participants on the latest internationa
Substance & Tax Law
In recent years tax authorities have placed more emphasis on combatting the use of abusive and aggressive tax structures by companies operating across borders, to ensure fair taxation.
The European Commission recently issued a new proposal (ATAD 3). It is highly recommended that taxpayers assess the possible impact of the proposal and consider opportunities for strengthening their local footprint and/or restructuring.
12-05-2022
During the 8th Annual International Tax Developments Seminar, several Loyens & Loeff tax experts as well as officials from the Dutch Tax Authorities updated the participants on the latest internationa
ATAD2
The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD2) aim to prevent situations of a double deduction and a deduction without a corresponding inclusion of the income at the level of the recipient resulting from a hybrid mismatch. All EU Member States have implemented ATAD2 in their domestic laws as from 1 January 2019 (for Belgium) or as from 1 January 2020 and 1 January 2022 (for a.o. the Netherlands and Luxembourg).
05-03-2021
Following the second EU anti-tax avoidance directive, the further implementation of the reverse hybrid rule entering into force as of 2022.
Digital Economy Tax
Politically it is clear that both the EU and other jurisdictions wants to levy more tax from ‘digital companies’. Technically, the current international tax framework does not facilitate this. Fundamental changes seem to be required to achieve the political goals. This could affect both digital and non-digital companies.
20-04-2022
On 4 April 2022 and 14 April 2022, the Task Force on the Digital Economy from the OECD published Draft Model Rules on the Scope and the Extractives Exclusion of Amount A of Pillar One.