International tax hot topics

On Tuesday, 23 November 2021 our webinar on the “International tax hot topics” took place.

OECD’s Two-Pillar solution that would overhaul existing international corporate tax rules
On October 8, 136 countries and jurisdictions agreed to an OECD-led plan to drastically reform international corporate tax rules. From 2023 onwards, the largest and most profitable multinational enterprises will be taxed a global minimum tax of 15% where they operate and earn profits. As multinational enterprises wait in anticipation for the further OECD release on the proposed model rules for Pillar 2, it is critical that groups grasp the key features of the OECD proposals and the potential impact these will have on their businesses.

Beneficial Ownership
After the European Court of Justice (ECJ) issued its judgments in the “Danish cases” in 2019, national tax authorities and courts are applying the ECJ’s judgment to scrutinize withholding tax exemptions on intra-group dividend and interest payments. Likewise, in Belgium, tax audits are abounding on this topic, leading to difficult discussions on who is considered as the beneficial owner of a payment; and specific substance levels required for holding or financing activities.

During the webcast covering the abovementioned international tax hot topics, KPMG experts discuss what the OECD’s implementation plan and the two-pillar proposal entails, as well as the main principles resulting from the Danish cases and how the beneficial ownership question is regarded in Belgium and other European Member States.