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The Q2 2024 edition of our Tax Newsletter Central Switzerland is now available, offering expert analysis on the most critical Swiss and international tax developments. From corporate tax updates to the latest in transfer pricing and indirect taxes, this issue is an essential read for businesses navigating today’s complex tax environment. https://lnkd.in/eAtwAMjC

Wealth and corporate taxes remain a sticking point between countries at the U.N. negotiating the roadmap for a framework convention on tax. The first round of talks to establish the parameters of the convention concluded last month. Read the story:

🚨 Pivotal ruling from The Tribunal of First Instance. Belgian taxpayers are allowed to deduct payments to tax havens if they can show it is ‘likely’ that the recipient entity was not set up to avoid Belgian income tax. This ruling offers useful guidelines for multinational corporations engaging with tax haven vendors. 🔍 Discover more in the insightful publication by our specialists Henk Vanhulle, Caroline Borgers, and Jan Van Cauwenberghe. https://lnkd.in/eMhZ8Nhk #TaxLaw #BelgiumTax #taxdeductions

Dear tax lovers, Update for Belgian Companies with Foreign Investments! Recent changes to Belgian CFC (Controlled Foreign Corporation) legislation could lead to increased tax burdens for your investments. If your Belgian company controls a foreign entity with an effective tax rate under 12.5% (based on Belgian tax rules), you might face additional taxes on the undistributed passive income of that foreign entity. Read more in our latest article:

🇵🇱 Pillar Two in Poland Has Become Official Exciting news from Poland! 🎉 As of yesterday, the Polish Government has officially published the relevant regulation for Pillar Two, set to come into force on 1 January 2025. Here's what you need to know: 1. 🇪🇺 **EU Version with Discrepancies**: Poland, an EU member, has implemented the EU version of the Pillar Two rules. There are some discrepancies between this version and the Model Rules. 2. 💼 **Complex Corporate Tax System**: Poland boasts a highly developed corporate tax system with multiple taxes at the country level. Ten of these are considered "Covered Taxes" under Polish regulations, despite the tax base stipulating wealth or expenditures for part of them. Thus, some may not be recognized as "Covered Tax" based on the Model Rules and the EU Directive, potentially adding extra burdens for MNEs. 3. 🌐 **Definition Misalignment**: The definition of "Covered Taxes" for taxes imposed in other jurisdictions doesn't fully align with the EU Directive and the Model Rules. For more specific details regarding the Pillar Two rules in Poland and possible discrepancies with the EU Law and the Model Rules, I recommend reaching out to Katarzyna Smoleń and Maksymilian Białek from Deloitte Poland. They frequently publish insights and conduct training sessions on this topic. #Pillar2 #Poland #Deloitte

OECD report to the G7 on Tax Cooperation delivered to the G7. Important recommendations on tax administration cooperation under GloBE, a mechanism for resolving disputes and opportunities for simplifying the international corporate tax system. Thanks to the team who helped put this together. https://lnkd.in/grbUWSjm

INTERNATIONAL TAX PLAZA - 2 Tax items are on the provisional agenda for the ECOFIN Council meeting of May 14, 2024 The next meeting of the Economic and Financial Affairs (ECOFIN) Council is taking place on May 14, 2024. The Agenda highlights and a provisional agenda for this meeting have been published on the website of the European Council/the Council of the EU. The following 2 tax items are mentioned on the provisional agenda. But again the proposal for an unshell Directive is not mentioned on the provisional agenda. https://lnkd.in/emyM3ehA

The first step before the first step in terms of the UN work on UN Tax Framework Convention. Namely, a “zero draft” from the 20 members Ad-hoc Committee that have been working on the draft for the Terms of Reference for a UN Tax Framework Convention. In simple words the Terms of Reference are the parameters on which the envisioned convention would be negotiated. So, this is the first draft of such parameters. Some comments on the release: - Input can be shared by the 21st of June 2024 - There seems that the release does not have the backing of all 20 members - The current version highlights some of the key areas aimed to be discussed under the framework convention (among others - allocation of taxation rights including for MNEs or the taxation of high-net individuals). Some of them overlap the work from the OECD at least in terms of perceived themes - One proposal that may generate debates is the suggestion that some specific areas should be developed simultaneously with the negotiation of the framework convention. There are mentioned: taxation of the digital economy, taxation of cross-border services, tax-related illicit financial flows, prevention and resolution of tax disputes & taxation of high-net individuals.

Canada’s Global Minimum Tax Act substantively enacted as part of Bill C-69 On 19 June 2024, Bill C-69, Budget Implementation Act, 2024, No. 1, received third reading in the House of Commons and became substantively enacted for Canadian financial reporting purposes. Among other measures, Bill C-69 includes a revised version of Canada’s Global Minimum Tax Act (GMTA), which was previously released for public comment last August. In this Tax Alert, we review certain key differences contained in the revised version of the GMTA. Learn more in our latest Tax Alert, Canada’s Global Minimum Tax Act substantively enacted as part of Bill C-69. Click here to view other recent Tax Alerts and follow us on LinkedIn: @EYCanada.

💡 Are you an expat looking to make the most of your Foreign Tax Credits? Wondering how to use carryover and carryback rules to maximize your savings? Our latest blog, "Foreign Tax Credit Carryover & Carryback Explained", breaks down everything you need to know about managing your foreign tax liability. Whether you're dealing with excess foreign taxes or just want to plan ahead, this guide is a must-read for U.S. expats! 🌍💼 👉 Check out the full article here: https://buff.ly/3XawgTP 🔗 Learn how to reduce your U.S. tax burden with smart foreign tax credit strategies. #ForeignTaxCredit #TaxSavings #USTaxes #ExpatTaxes #TaxPlanning #TaxTips #1040Abroad