Loyens & Loeff’s Post

Hope to see you on 29 October during our EU Tax Law seminar in Cape Town (IFA)! #Loyensloeff #stateaid #transferpricing #EUtaxlaw

ICYMI last week: The American Free Enterprise Chamber of Commerce, a US business group with ties to former Trump admin Attorney General *Bill Barr*, filed a legal challenge to Belgium's global minimum tax law. The goal, according to the group, is to invalidate the global minimum tax rules in the EU altogether. “AmFree’s objective is to obtain a ruling from the Court of Justice that Pillar II is unlawful which will affect Pillar II in the EU as a whole and, as a practical effect, make it unenforceable in all European Union Member States,” the group said in its statement. Read more from me in the link below: #InternationalTax #OECD #GlobalMinimumTax #PillarTwo #CorporateTax #EuropeanUnion #Belgium #BillBarr #UScompanies #CrossBorderTaxation https://lnkd.in/eusJ8RwU

EU Law Live´s Competition Corner 10th Symposium, "Selectivity in State Aid" is happy to bring you María López Ridruejo and Alexandre Picón´s article today! The authors aim to analyze the Court of Justice's ruling on the Spanish Tax Lease scheme, emphasizing the role of the discretionary powers of public authorities in determining the selectivity of tax measures as state aid. The discussion highlights the complexities and legal precedents involved in assessing the discretion exercised by tax administrations in granting tax advantages. Read more at EU Law Live: https://lnkd.in/dgBN6KU3   Stay tuned! Much more to come! #EU #competitionlaw #taxlaw #fiscallaw #publicauthorities #publicadministration #europeanlaw #stateaid #CJEU

💡 Significant shift in tax policy - the Latvian government has approved the global minimum tax law. It's crucial to conduct calculations considering Latvia's unique corporate income tax system to ensure compliance and readiness for the eventual implementation. Though the application in Latvia is postponed, group companies located in other countries should conduct calculations for Latvian entities and pay additional tax if effective tax rate does not reach 15%.  📌 Staying informed and prepared will help businesses navigate this evolving tax landscape effectively. #GlobalMinimumTax #Latvia #EYTax #TaxCompliance

[NEW EVENT ✅] Join our upcoming conference: "Tax reform in Belgium: how to develop a fair tax system?" in the offices of TreeTop Private 🗣️ Our speaker: - Mark Delanote, Professor Ghent University and Lawyer at DELANOTE LAW 📌Wednesday 21 February 2024 at 6.15 pm ❓How do we define fairness in taxation? ❓What are the features of an optimal tax structure? ❓How is this reflected in the tax mix ad how does this affect the taxation of labour, capital and consumption? Register: https://lnkd.in/eNVStyFp

𝗖𝗝𝗘𝗨 𝗿𝘂𝗹𝗲𝘀 𝘁𝗵𝗮𝘁 𝗗𝘂𝘁𝗰𝗵 𝗶𝗻𝘁𝗲𝗿𝗲𝘀𝘁 𝗱𝗲𝗱𝘂𝗰𝘁𝗶𝗼𝗻 𝗹𝗶𝗺𝗶𝘁𝗮𝘁𝗶𝗼𝗻 𝗿𝘂𝗹𝗲 𝗶𝘀 𝗻𝗼𝘁 𝗶𝗻 𝗯𝗿𝗲𝗮𝗰𝗵 𝗼𝗳 𝗘𝗨 𝗹𝗮𝘄 Today, the Court of Justice of the European Union (CJEU) ruled that the Dutch interest deduction limitation rule of Article 10a Corporate Income Tax Act 1969 (CITA) is compatible with EU law. The CJEU found that, although Article 10a CITA restricts the freedom of establishment, such restriction can be justified because the legislation pursues combatting tax avoidance, as its application is limited to wholly artificial arrangements. The CJEU provides some guidance on wholly artificial arrangements and clarifies its judgment in Lexel. Read more: https://lawand.tax/4gOWFiZ For more details, reference is made to our Tax Flash written by Dennis Weber, Joost Van Helvoirt, Pierre-Antoine Klethi, Laurens Winkenius and Guido Bentveld. Any questions? Please feel free to reach out to your trusted adviser at Loyens & Loeff. #eutax #netherlands #interestdeduction #corporates #lawandtax

📍 Last April 29th, the European Council adopted a reform of fiscal rules aimed to ensure sound and sustainable public finances. In this context, tax collection became the main tool to be used by public Administrations to increase revenues. Our #RocaJunyent professionals, Raul Salas Lucia, Tax Law Partner, and Elena Ferrer-Sama Server, Tax Law Area Director, are the key contributors to Legal 500's Tax Comparative Guide in Spain. In this prestigious publication, which covers several jurisdictions, our professionals share their knowledge, offering an overview of #taxlaws and regulations applicable in #Spain.  👉https://lnkd.in/dz4FAHqe

In this blog post our managing director Jakob Bundgaard reflects on current tax policy developments: Global Tax Policy Trends – From Coordination to Conflict? - Kluwer International Tax Blog (kluwertaxblog.com)

On July 12, 2024 the Swiss Federal Council and the Government of Hungary signed a Protocol to amend the Convention between the Swiss Confederation and Hungary for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital signed at Budapest on 12 September 2013 (hereinafter: “the Convention”). Considering the ongoing discussions on whether or not the implementation of Pillar 2 is compatible with international law this Protocol a.o. contains a very interesting Article regarding the implementation of Pillar 2. https://lnkd.in/eqqq6c4C

𝐋𝐞𝐱𝐨𝐥𝐨𝐠𝐲 𝐢𝐧-𝐝𝐞𝐩𝐭𝐡: 𝐓𝐚𝐱 𝐃𝐢𝐬𝐩𝐮𝐭𝐞𝐬 𝐚𝐧𝐝 𝐋𝐢𝐭𝐢𝐠𝐚𝐭𝐢𝐨𝐧 𝐢𝐧 𝐁𝐞𝐥𝐠𝐢𝐮𝐦   Caroline Docclo authored the Belgian chapter for the 2024 edition of Lexology in-depth - Tax Disputes and Litigation. This guide provides a practical overview of tax dispute issues across key jurisdictions, with Caroline detailing Belgium's tax dispute resolution framework.   Belgian tax procedures generally do not require fees for engagement with tax authorities or courts. While tax procedures can be slow, administrative resolutions are common through open discussions with tax authorities. Services like the Ruling Commission and the Tax Conciliation Service provide assistance in preventing or resolving disputes.   👉 Read the full article on our website: https://lawand.tax/3xGhhIy #tax #belgium #taxdisputes #litigation #lawandtax