In Brief from International Taxation [January 2021]
Reports on exchange of financial account information and guidance on the transfer pricing implication of the COVID-19 pandemic were published by the OECD. ECOFIN expressed their support for the implementation of DAC 7. Divided distribution by Gibraltar companies to eligible Luxembourg entities will be subject to dividend withholding tax as of 1 January 2021. The French Supreme Administrative Court ruled on the interpretation of tax treaties and PE concept. New PE rules were introduced also in Denmark. Other interesting news refers also to tax changes in Portugal, Belgium or US.