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Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Guido Arie Petraroli and Francesco Cardone of LED Taxand analyse the DAC6 Directive in Italy focusing on the tax saving test, main benefit test and hallmark C1, in relation to inter-company debt financing.
René Matteotti, Peter Vogt and Natalja Ezzaini of Tax Partner AG examine how Swiss authorities have sought to address tax queries concerning cross-border workers, which have emerged from the coronavirus pandemic.
Costas Savva and Demis Ioannou of Taxatelier take a closer look at protective tax measures for excessive debt financing, and consider whether the new FT Report can be a solution for existing problems.
