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On September 26, 2024 the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) is publishing a Model Competent Authority Agreement (MCAA) to facilitate the implementation of its political commitment on Amount B of Pillar One. This practical tool is designed to be particularly beneficial for jurisdictions with limited resources and data availability.
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On September 10, 2024 on the website of the Court of Justice of the European Union (CJEU) the judgment of the CJEU in Case C-465/20 P, Commission v Ireland and Others, ECLI:EU:C:2024:724, was published.
Today the CJEU gave final judgment in the matter, sets aside the judgment of the General Court and gives final judgment in the matter and confirms the European Commission’s 2016 decision that Ireland granted Apple unlawful aid which Ireland is required to recover. By doing so, the CJEU ruled in line with the opinion of Advocate General Pitruzella as delivered on November 9, 2023.
As a result of todays judgment Apple will have to pay an additional €13 billion of Irish taxes.
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On September 9, 2024 the Australian Treasury issued a press release that on that same date the Governments of Australia and the Republic of Slovenia had signed a Convention for the elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (Hereinafter: the Convention).
Although the Convention has been signed, it has not entered into force yet. For the Convention to enter into force, the respective ratification procedures have to have been finalized in both jurisdictions.
Below we will discuss a selection of provisions included in the Convention of which we think they might interest our readers.
Read more: Australia and Slovenia have signed a Tax Convention
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During its meeting of September 4, 2024 the Swiss Federal Council decided to bring the income inclusion rule (IIR) into force with effect from January 1, 2025. This international supplementary tax will complement the Swiss Qualified Domestic Minimum Top-up Tax (QDMTT) that already came into effect on January 1, 2024.
Read more: The Income Inclusion Rule (IIR) to come into force in Switzerland in 2025