Tax Law and International Tax Law

Cyprus continues to strengthen its position as a leading international business and investment hub through the expansion and modernisation of its Double Tax Treaty (DTT) network. These treaties help businesses and individuals avoid being taxed twice on the same income while providing greater certainty for cross-border investments and international operations.

Italy is one of the world's leading destinations for luxury yachts. Every year, thousands of vessels sail through Italian waters, berth in prestigious marinas and enjoy the Mediterranean coastline. Alongside this thriving maritime sector, however, Italian customs authorities have significantly increased inspections involving foreign-flagged yachts, imported vessels and cross-border maritime operations.

European financial sector tax reform is imminent, with the European Parliament and Commission acknowledging that current VAT exemption rules from the 1970s no longer reflect modern fintech business models. Leaders of digital banks, payment companies, and financial platforms face a critical window to influence policy outcomes that will fundamentally reshape their tax obligations and competitive positioning.

As its European customer base continued to expand, a US-based distributor of industrial equipment found that its existing business model was no longer suited to its long-term growth ambitions.

Malta’s corporate tax regime is designed to support international businesses, offering a compliant and flexible framework for companies operating across borders.

Cyprus holding companies offer founders, investors, and group owners a strategic vehicle for profit distribution, reinvestment, and exit planning while minimizing tax leakage and withholding tax exposure. This structure provides significant advantages for international business operations and capital efficiency.

At its core, the case concerns a Luxembourg holding company (the “Company”) that had contractually agreed to bear the credit risk on loans managed by a related entity’s permanent establishment located in Luxembourg (the “Branch”), without disclosing this arrangement to the Luxembourg tax authorities (the “LTA”) and without receiving any compensation.

Malta is consolidating four existing tax programmes into a unified Individual Tax Programme framework, effective January 2027. The new rules introduce significantly higher minimum tax thresholds, increased property requirements, and stricter application fees while maintaining the attractive 15% flat tax rate on foreign-sourced income remitted to Malta.

Cyprus IP Box Process Explained (3% Total Tax for Technology Companies)

At its core, the case concerns a Luxembourg holding company (the “Company”) that had contractually agreed to bear the credit risk on loans managed by a related entity’s permanent establishment located in Luxembourg (the “Branch”), without disclosing this arrangement to the Luxembourg tax authorities (the “LTA”) and without receiving any compensation.

In its decision of 22 July 2026 (case 53194C), the Luxembourg Administrative Court, the Luxembourg court of appeal in tax matters, rendered an important transfer pricing judgment concerning the application of the arm's-length principle to the restructuring of intra-group debt and the deductibility of interest expenses.

The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.