Further to the publication of the G20/OECD inclusive framework on BEPS’ Global Anti-Base Erosion Model Rules (Pillar Two) designed to ensure a global minimum level of taxation for multinational groups
It is also worth noting that the EC announced its intention to expand the scope of the Directive on Administrative Cooperation to facilitate the exchange of information in relation to minimum taxation rules under Pillar Two (referred to as “DAC9”). A draft proposal is expected once further pr...
Bearing in mindthat every single change to the text will need to be adopted by the unanimity of Member States, we would strongly urge the EU Council and the European Commission to take into account the remaining work of the OECD on Pillar II before finalising the text of the Directive. Oth...
However, that 25% threshold is a different way of defining a group compared to the criteria defined in BEFIT and Pillar Two, which could cause difficulties in coordinating the different regulations. Finally, the TP Directive clarifies that a permanent establishment is an associat...
The present paper examines two important and up-to-date topics in labour law. First, the analysis focuses on the general aspects and the significance of the European Pillar of Social Rights (EPSR), which is the most recent legal source – except for a couple of direc...
Article 44 of the Minimum Tax Directive sets out the requirements on filing for in-scope entities, referring to a Top-up tax information return, which must be filed using a standard template and include certain specified data points. Under Article 44, there are two options for ...
On 11 May 2022, the EU Commission issued adraft directiveproposing a debt-equity bias reduction allowance (the “DEBRA Proposal”). The DEBRA Proposal lays down rules (i) to provide, under certain conditions, for the tax deductibility of notional interest on increases in eq...
Through enhanced corporate reporting, EY can support finance teams to meet demands for high-quality enhanced financial and nonfinancial information. Read more Related content Five priorities to build trust in ESG ESG investing is at a critical moment. As historical levels of capital are...
General Court Dismisses Action for Annulment of the Pillar Two Directive January 03, 2024 Download PDF - 121 KB CJEU Rules That Portuguese Additional Solidarity Tax on the Banking Sector Legislation Is Not in Line With EU Law December 18, 2023 Download PDF - 139 KB The Court of Jus...
General Court Dismisses Action for Annulment of the Pillar Two Directive January 03, 2024 Download PDF - 121 KB CJEU Rules That Portuguese Additional Solidarity Tax on the Banking Sector Legislation Is Not in Line With EU Law December 18, 2023 Download PDF - 139 KB The Court of Jus...