International Fiscal Association’s Post

Update on the Pillar Two front in Switzerland! A QDMTT will be introduced as per 1 January 2024. By contrast, the Federal Council has decided to initially refrain from applying the international supplementary tax rules IIR and UTPR. In this regard, it will continue to monitor international developments and decide about implementation at a later date, should this prove necessary in order to preserve Swiss interests.

In August 1920, the Dutch government presented a proposal for a tax treaty to their southern neighbors. This proposal was simple, principle based and similar to other early tax treaties being negotiated by European nations at the time. The initiative for the first comprehensive Double Taxation Agreement (DTA) between the countries stemmed from a Belgian appeal to resolve the issue of double taxation resulting from war profits taxes, mobilization tax, and other extraordinary taxes. More than hundred years later extraordinary taxes are on the rise again. What is different is that a comprehensive treaty network is in place, with treaty provisions that have grown more complex over time. Do they sufficiently address newly emerging tax issues? The Netherlands and Belgium are currently ratifying a revised tax treaty that will be the subject of a bilateral IFA Conference on 6 September 2024. Programme, speakers and registration are available at https://lnkd.in/gqxJPQVt. Join experts from government, practice, business and academia to explore the new convention between Belgium and the Netherlands and other international tax developments in the Low Countries. Registration is now open at a reduced rate for all IFA members! #IFAT #tax #internationaltax #taxtreaties #belastingverdrag #NederlandBelgië International Fiscal Association - Young IFA Network YIN - Young IFA Network (YIN Netherlands) - Women of IFA Network (WIN) - Bernard Peeters - IFA BELGIUM - Rhys Bane - Mahi Anastasiou - Linda Brosens - Wim Panis - Laurence Pinte - Frank Pötgens - Margriet Lukkien - Gijs Fibbe - Caroline Docclo - Rijkele Betten - Tim Wustenberghs

Update on the Pillar Two front in Switzerland! A QDMTT will be introduced as per 1 January 2024. By contrast, the Federal Council has decided to initially refrain from applying the international supplementary tax rules IIR and UTPR. In this regard, it will continue to monitor international developments and decide about implementation at a later date, should this prove necessary in order to preserve Swiss interests. https://lnkd.in/e2gz4H8w

News from the network of tax treaties signed by France, by Cédric PHILIBERT, Clément BOULO and Erwan Cherfaoui.  This article presents recent developments in France and in other countries or international organisations that have an impact on bilateral tax treaties signed by France.  Find this article in the issue 4-2023 of the Fiscalité Internationale Review (https://lnkd.in/eMw7B-YR). To receive by e-mail the news published on the Review's website, subscribe to the free news feed (https://lnkd.in/es-PAAvH).   #internationaltaxation #taxation #taxlaw 

News from the network of tax treaties signed by France, by Cédric PHILIBERT, Clément BOULO and Erwan Cherfaoui.  This article presents recent developments in France and in other countries or international organisations that have an impact on bilateral tax treaties signed by France. Find this article in the issue 2-2024 of the Fiscalité Internationale Review (https://lnkd.in/eMw7B-YR). To receive by e-mail the news published on the Review's website, subscribe to the free news feed (https://lnkd.in/es-PAAvH).   #internationaltaxation #taxation #taxlaw 

News from the network of tax treaties signed by France, by Cédric PHILIBERT, Clément BOULO and Erwan Cherfaoui.  This article presents recent developments in France and in other countries or international organisations that have an impact on bilateral tax treaties signed by France. Find this article in the issue 1-2024 of the Fiscalité Internationale Review (https://lnkd.in/eMw7B-YR). To receive by e-mail the news published on the Review's website, subscribe to the free news feed (https://lnkd.in/es-PAAvH).   #internationaltaxation #taxation #taxlaw 

📢 𝘈𝘶𝘴𝘵𝘳𝘪𝘢 𝘈𝘮𝘦𝘯𝘥𝘴 𝘊𝘍𝘊 𝘙𝘶𝘭𝘦𝘴 𝘵𝘰 𝘈𝘷𝘰𝘪𝘥 𝘋𝘰𝘶𝘣𝘭𝘦 𝘛𝘢𝘹𝘢𝘵𝘪𝘰𝘯 𝘶𝘯𝘥𝘦𝘳 𝘗𝘪𝘭𝘭𝘢𝘳 𝘛𝘸𝘰 Austria has recently amended its Controlled Foreign Companies (CFC) rules to align with the EU’s Pillar Two Directive, aimed at preventing economic double taxation for multinational enterprises. 𝐊𝐞𝐲 𝐇𝐢𝐠𝐡𝐥𝐢𝐠𝐡𝐭𝐬: ◼️ 𝘊𝘍𝘊 𝘙𝘶𝘭𝘦𝘴 𝘜𝘱𝘥𝘢𝘵𝘦𝘥: Foreign Qualified Domestic Minimum Top-up Taxes (QDMTTs) are now included in Austria’s CFC tax calculations, preventing double taxation. ◼️ 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘯𝘨 𝘊𝘪𝘳𝘤𝘶𝘭𝘢𝘳 𝘌𝘧𝘧𝘦𝘤𝘵𝘴: The amendment addresses the potential for circular effects, where foreign passive income could be taxed both locally and again under Austria’s CFC rules, even after applying a QDMTT. ◼️ 𝘉𝘦𝘯𝘦𝘧𝘪𝘤𝘪𝘢𝘭 𝘖𝘶𝘵𝘤𝘰𝘮𝘦 𝘧𝘰𝘳 𝘛𝘢𝘹𝘱𝘢𝘺𝘦𝘳𝘴: The amendment could lead to more favorable tax outcomes, as it avoids the higher 23% Austrian corporate tax rate by recognizing foreign QDMTTs, ensuring only the 15% minimum tax rate applies. 🔗 𝐑𝐞𝐚𝐝 𝐦𝐨𝐫𝐞: https://lnkd.in/dCK4YmBs Authors: Matthias Mitterlehner, Valentin Bendlinger 🔍 For tailored advice, reach out to our member firm in Austria, ICON Wirtschaftstreuhand GmbH WTS Global Locally rooted - Globally connected #wts #wtsglobal #tax #taxtion #taxnews #taxinsights #corporatetax #pillartwo #austria #businesseurope

Which of the priority areas from the proposal for Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation is most relevant to you? #Taxation of income from cross-border services was chosen as a relevant item to monitor by more than 40% of participants to a recent KPMG webcast, with taxation of the digitalized and globalized economy coming in second. Many stakeholders are concerned by the prospect of a duplication in the #UN Ad Hoc Tax Committee of the work already done at the level of the #OECD on the latter topic. This is a valid concern that must be balanced against the potential benefits from the establishment of fundamental principles to ensure fully inclusive consultation on substance and process, a system of governance for international tax cooperation and the establishment of an inclusive, fair, transparent, efficient and equitable international tax system. This view and other relevant points are reflected in the KPMG comments on the zero draft, available on the public consultation page: https://lnkd.in/df5KBUgP For a discussion on the direction of travel at the level of the UN and other international tax and EU hot topics, sign in to listen to the playback: https://lnkd.in/dJEXC-43 Marco Dietrich Ana Puscas Michael Freudenberg Nina Matvienko Vinod Kalloe Grant Wardell-Johnson David Wren Begüm Onar

Pillar One, Amount A is coming - In a significant stride towards international tax reform, the OECD's optimism of the anticipated signing of the Multilateral Convention (MLC) implementing Amount A of Pillar One is high. This is according to a statement by the Co-Chairs following the 16th meeting of the OECD/G20 Inclusive Framework on BEPS which happened last week in Paris. A key objective of the MLC is to enhance tax certainty and to phase out digital service taxes, which have been a point of contention in international tax discussions. As we approach the signing, the business and tax communities will be looking at the implementation of these new rules addressing how taxing rights are allocated between countries in the digital age. #OECD #TaxReform #GlobalEconomy #DigitalTax #BEPS #MLC #PillarOne

The latest E-News edition from KPMG's EU Tax Centre has been released! Highlights include: 💡 European Commission: Public consultation on the Directive on Administrative Cooperation (DAC) 💡 Council of the EU: Belgian Presidency reaches agreement on FASTER 💡 OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples 💡 Belgium: Amendments to the Pillar Two global minimum tax rules adopted 💡 Denmark: Legislative proposal to amend Pillar Two legislation submitted to Parliament 💡 Italy: Tax authorities issue regulations on optional alternative to controlled foreign company taxation 💡 Poland: Consultation on legislative proposal to implement minimum taxation under Pillar Two 💡 France: French Supreme Administrative Court rejects claim for cross-border loss relief Raluca Enache Ana Puscas Marco Dietrich Nina Matvienko Alexandra Baudart Erwan Cherfaoui #futureoftax #kpmgtax