The United Arab Emirates has introduced economic substance legislation, Cabinet Resolution No. 31 of 2019, with the aim of being removed from the European Union’s blacklist of uncooperative jurisdictions. The blacklisting was announced in March, after the EU’s Code of Conduct Group (Business Taxation)  (CCG) named the UAE as one of the jurisdictions it considered...Read More

Brazil and Uruguay have included provisions to tackle base erosion and profit shifting in a new double tax agreement, signed on June 7, 2019. The Brazilian Government said the conclusion of the agreement reflects the country’s efforts to expand and modernize its network of tax agreements. It has now signed 37 double tax pacts, of...Read More

HMRC’s powers to demand information from non-residents have been further extended by the First-tier Tax (FTT) tribunal to include ex parte third-party information notices. Until this year, it was generally thought that HMRC’s powers to compel disclosure do not extend to individuals resident in overseas jurisdictions. That view was originally supported by the First-tier Tax...Read More

Italy’s special tax regime for newly resident workers (lavoratori impatriati) has been extended by decree this month, significantly broadening its size and scope. The tax exemption for Italy-sourced income is no longer restricted to qualified professionals, managers, executives or high-prestige entrepreneurs. It is now open to any workers who were non-resident during the two previous...Read More

Luxembourg imposes reporting requirements on companies operating in blacklisted countries   The Luxembourg tax authority is the first to officially announce sanctions against jurisdictions designated by the European Union as ‘non-cooperative’ for tax purposes. Under Circular LG-A no.64, Luxembourg resident companies must state in their tax return if they have entered into transactions with ‘related enterprises’...Read More