International Corporate Tax

In April 2026, the Turkish President and the Minister of Finance brought forward a legislative proposal that we expect to enter into force in the next few weeks.

Implementation of Council Directive (EU) 2016/1164 of 12 July 2016 Status as of 1 January 2026

The PE concept for income tax purposes is therefore far more than just a tax law concept. We therefore consider it our responsibility to provide our clients with a practical, hands-on tool that offers initial guidance in navigating the complex landscape of international permanent establishments.

We are thrilled to share with you a roundup of significant updates from December 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you a roundup of significant updates from June 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you a roundup of significant updates from May 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

With Pillar Two enacted in over 25 jurisdictions, it's crucial for calendar-year companies to understand the forecasted impacts on their Q1 2024 income tax provisions. Discover the checklist of action items curated by GTM, our member firm in the US, to navigate the complexities of new tax regulations.

As remote work becomes more prevalent, companies need to be aware of the tax issues associated with their employees’ presence in foreign jurisdictions.

Remote working has increased significantly since the beginning of COVID-19.

The Pillar II initiative adapts the taxation of large groups to appropriately consider digitalisation and globalisation.

The Supreme Court of Pakistan has recently ruled on the Snamprogetti Engineering case, adjudicating the controversy involving the existence of a permanent establishment and chargeability to tax of Pakistan-source income under the Pakistan-Netherlands Double Taxation Treaty.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

The Belgian government submitted its proposal for a mandatory B2B invoicing scheme.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

Christian Schiessl becomes new Co-Head of the International Corporate Tax (ICT) Service Line at WTS Global

Germany had already applied for the introduction of mandatory electronic invoicing as a special measure under Art. 395 of the VAT Directive in 2022. By decision of 25 July 2023, the Council of the European Union approved this approach.

This article examines the Paris Administrative Court of Appeal's ruling on corporate income tax and residency, reshaping how tax treaties are interpreted.

A comprehensive guide to the latest in corporate tax strategies and regulations across Latin America.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

Since 1 April 2020 all public organisations and private companies can require e-invoices from their suppliers in Finland.

The digital age has led to a growing need to combat VAT fraud, minimize the VAT gap and modernize the EU's VAT system in response to the demands of today’s digital economy.

Spanish Act 18/2022 of September 28 on company creation and growth introduces a range of new measures including the e-invoice, which is mandatory for all exchanges between businesses and professionals.

Starting from 1 January 2024, invoices for B2B transactions having the place of supply in Romania must be submitted through the RO e-Factura system. 

In its decision of 23.3.2023 the Austrian Supreme Administrative Court declined the qualification of a Cyprus-based intermediary holding company for a refund of Austrian withholding taxes on dividend payments under the EU Parent Subsidiary Directive.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

New Law No. 7456 introduces significant changes to tax legislation and provides support to employers in the aftermath of the 2023 earthquakes.

Find out the latest on the implementation of public CbCR in the Netherlands and what it means for multinational enterprises. Discover key details and important next steps in this newsflash.

Discover the latest insights from Lee & Ko, our trusted tax experts in South Korea, in their article published in Bloomberg Tax. Uncover the groundbreaking developments of South Korea's Pillar Two rules and explore their implications for foreign multinational enterprises operating in the country.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

The Supreme Court declares the existence of discrimination in the taxation of non-resident hedge funds when receiving dividends from Spanish companies

1 March 2023 saw the amended protocol to the double taxation agreement between the United Arab Emirates and Austria enter into force. Whilst the protocol has various implications for residents of Austria, the changes regarding withholding tax on dividends mainly affect residents of the UAE.

On 8 January 2023, the six-month grace period lapsed from the notification of the United Sates to Hungary regarding the termination of its double tax treaty. 

Effective from 1st January 2023, the Law introduces a range of tax measures that multinational enterprises (MNEs) operating in Italy may find noteworthy.

The Federal Government has enforced certain taxation measures through promulgation of the Finance (Supplementary) Act 2023, effective from 24 February 2023.

As of 2022, Polish CIT regulations contain a new definition for beneficial owner. The Voivodship Administrative Court in Lublin examined complaints against the refusals to issue preference opinions, presenting its own assessment of genuine business activity criteria.

In the long-standing conflict regarding the harmonisation of domestic general anti-avoidance rules (“GAARs”) vs treaty law, the Argentine Tax Court sided with the Argentine Revenue Service in an attempt to enhance the goals and principles contained in the Argentine Double Tax Conventions.

The Spanish Government has approved several tax measures which have come into force in 2023.

Although provisional measure 1152/22 is generally known for introducing new Transfer Pricing rules in Brazil, aiming at an alignment with the OECD standards, it also provides for relevant new rules on the deduction of royalties for Corporate Income Tax and social contribution on profits purposes.

For the benefit of the tax deductibility of credit losses enshrined in the IFL 2023, banking and financial institutions are required to meet certain substantive and formal requirements.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

Turkey launches new Corporate Tax Law No. 7440 on Tax Amnesty and Tax Debt Restructuring including a one-off so-called “earthquake tax”.

On 20 December 2022, the OECD/G20 GloBE Inclusive Framework released its Pillar Two Safe Harbour and Penalty Relief guidance document. Read an article about the key elements of the transitional and potential permanent safe harbours from our tax experts in Belgium.

The Finance Ministry published an announcement dated 20 Dec 2022 on the base rate and margin notice for transfer pricing purposes in personal income tax (PIT) and corporate income tax (CIT). The announcement came into force on 1 January 2023.

In a recent case, the Austrian Fiscal Court had to decide whether withholding taxes that cannot be fully credited in the respective tax year can be carried forward to the following years.

15 December 2022 saw the Council of the European Union reach its unanimous agreement on the “Council Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups” in a written procedure.

The fundamental purpose to introduce PHC regulations was to increase the attractiveness of Poland as a location for setting up holding companies.

Ship pooling arrangements have become more common as shipowners seek greater efficiencies in the deployment of their vessels.

As of 30 August 2022, the Argentine Revenue Service (“ARS”) decided to suspend the Mandatory Disclosure Framework (“MDF”), which was created by the agency by means of general resolution no. 4838/2020, enacted in October 2020.

The approval of the Multilateral BEPS Convention contains the list of reservations and notifications made by the Chinese government, which becomes effective from 1 September 2022.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

On 1 June 2022, the Austrian Ministry of Finance (MoF) issued a statement (EAS 3436), saying that it is changing its understanding of how certain IT services are qualified in the double tax treaty (DTT) with China.

In its decision, the French supreme tax court (Conseil d’Etat) had to decide whether, in the presence of intermediary companies, the treaty with the state of residence of the beneficial owner should be applied

Digital service tax is covered in the OECD’s Pillar One. If Pillar One is finally released, digital service tax that is unilaterally implemented must be abolished.

Traditionally, the government of Kenya has been introducing changes to tax laws every year, mainly through an annual finance act.

The Argentine Revenue Service (“ARS”) considered that the Belgium Company Solvay S.A. (“Solvay”) had a PE in the country during the years 2001 to 2006

The federal government has recently introduced various changes in the corporate tax rate structure with the Finance Bill 2022.

The Amsterdam Court of Appeal denied the dividend withholding tax exemption for a distribution to a Belgian family holding company due to lack of substance.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

The document analyses the provisions contained in the Articles 6 to 11 of the Legislative Decree 142/2018.

The Pillar Two model has started a new chapter for international taxation when dealing with the challenges of globalisation and digitalisation. As the world’s second-largest economy, China has actively participated in the discussion and implementation of the Pillar Two model.

The Argentine Supreme Court (“ASC”) ruled on the Molinos case, a milestone one related to treaty shopping.

Recently, the highest level of the Federal Administrative Tax Court (CSRF) changed its longstanding view on the overlapping of Article 7 of the Double Tax Treaty (DTT) and the Brazilian Controlled Foreign Corporation (CFC) rules, now favouring taxpayers. 

On 20 December 2021, the OECD published the model rules on global minimum taxation (“Pillar Two”), on which around 140 countries have agreed as part of the work of the OECD's Inclusive Framework.

Uncertainties relating to the determination of the profits attributable to a construction/installation permanent establishment (PE) are a substantial tax-related project risk for companies within the plant construction sector.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

The Austrian Administrative Supreme Court (Verwaltungsgerichtshof) had to deal with a trademark licensing between Malta and Austria. The Austrian trading company MCo had demerged its business and real estate to the Austrian company XCo in 2007. The trademarks stayed with MCo.