Fiscalité Internationale’s Post

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

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 

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 4-2024 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 

The New Era of Taxation - one of the most exiting tax conferences, organised by Taxes Committee of International Bar Association where you can not only meet tax lawyers all over the world, but also to discuss on all trending tax topics. This year this meeting is organised in beautiful Lisbon, which spoils us with sun and warmth. But even more, this time was even more special for me, as together with Mariana Eguiarte Morett Josh Kumar Shreya Rao Karin Spindler-Simader and Francisco Cabral Matos we had fruitful panel discussion on Recent cases and trends on beneficial ownership and treaty eligibility. Two take-aways: 1. There is still open question, if beneficial ownership rule and the concept itself has the purpose to fight against avoidance of tax and treaty shopping or is it the rule for attribution of income; and 2. Why tax authorities throughout the world would still tend rather to apply all kind of domestic rules (GAAR or SAAR) instead of application of provisions of double tax treaties. And one bonus message - the market is awaiting for the news from CJEU, as it needs much more clarity after the situation, created by Danish cases… Special thanks for the hosts of the conference Serena Cabrita Neto and Tiago Cassiano Neves. #ibataxescommittee #taxconference #wallesstax

Recent cases and trends in beneficial ownership and treaty eligibility were some of the key topics at The New Era of Taxation conference, hosted by the International Bar Association’s Taxes Committee. WALLESS Partner Dr. Aiste Medeliene joined a panel of tax experts to discuss these issues and their impact on global tax practices. Here are Aistė's key takeaways: • The purpose of the beneficial ownership rule remains under debate: is it aimed at combating tax avoidance and treaty shopping, or is it primarily a framework for income attribution? • Globally, tax authorities often prioritize domestic rules (GAAR or SAAR) over double tax treaties, highlighting a lack of consistency that could shape future tax policy. • Bonus insight: the market is eagerly awaiting an update from the The Court of Justice of the European Union, as clarity is needed following the uncertainties raised by the Danish cases. As tax policies and global practices change, WALLESS is glad to take part in creating a more connected international tax landscape. #tax #insights #InternationalBarAssiciation

Taxation of industrial property products: a tax director’s view of the French 2018 reform, by Alfred de Lassence. The 2019 Finance Act brought the French tax regime favouring R&D activity (art. 39 terdecies of the French Tax Code) into line with the OECD recommendations. Primarily, the new regime, now codified in Article 238 of the French Tax Code, aligns the locations of R&D activity and the tax benefit derived from the exploitation of the resulting intangible assets (‘Nexus’). After five years of application, the tax director of a major French industrial group gives us his views on this reform. Find this article in the issue 3-2024 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 

[🔥 #NewsFlash] - Upcoming Tax Reductions and Incentives for Corporations and Individuals in Luxembourg. On July 17, 2024, the Luxembourg government introduced draft law n°8414, which aims to enhance the country's competitiveness by implementing favourable tax measures for both corporations and individuals (the "Draft Law"). This follows the general policy statement made by the government earlier this year. Additionally, some proposed tax measures seek to clarify and further structure the existing tax regime for specific entities, such as the SPFs ("Sociétés de Gestion de Patrimoine Familial"). On July 22, 2024, the Luxembourg direct tax authorities released a newsletter confirming that most of these tax measures will come into effect starting from the fiscal year 2025, except for certain exceptions that are detailed below. ➡ Read more in our latest newsflash here: https://lnkd.in/eFqPThVc 📧 For more information, contact our experts: Julie Carbiener, Camille Bénézet, Pietro Casablanca, Nicolò Lamperti

Unlock tax savings in Luxembourg! Whether you're a business aiming to boost your bottom line or an individual looking to maximize your savings, these new measures are designed just for you! 💼💰 Click to explore more about this topic and do not hesitate to contact us for further details! 📈✨

A Norwegian 🇳🇴 company has a subsidiary in Switzerland 🇨🇭, and it received dividends from that subsidiary. The Norwegian Tax Administration (Skatteetaten) 🧾 taxes that dividend distribution a certain way, and did not give the distribution a potentially applicable exemption the company was looking for, because Norwegian 🇳🇴 tax law describes Switzerland 🇨🇭 as a 'low tax' jurisdiction. Is this in conformity with the EFTA Convention? 🇮🇸🇱🇮🇳🇴🇨🇭 The Appeals Committee of the Supreme Court of Norway (Høyesteretts ankeutvalg) 🇳🇴⚖️ has confirmed the Supreme Court will hear and decide the case. More on the NIELS website: https://lnkd.in/dUVJ-QDy #EFTA #Høyesterett #TaxedDividends