The European Commission has formally requested that Germany amends its anti-abuse provisions on withholding tax relief. While not criticising the aim of the anti-abuse measure, the Commission is concerned about the disproportionality of one provision under which companies have to prove the existence of genuine economic activity of their foreign subsidiaries to obtain the relief.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test