Tax Law and International Tax Law

Explore recent developments in Luxembourg tax law, including administrative court rulings on interest-free loans, corporate tax losses, and share premium repayments. ATOZ provides expert analysis on transfer pricing disputes, the new impatriates regime, and Pillar Two GIR filing exemptions that impact multinational corporations and investment structures.

The principal provisions concern the transposition into Greek law of two EU Directives — 2023/2226 and 2025/872 (DAC8 and DAC9, respectively) — through amendments to Law 4170/2013 (the Law), the framework statute governing administrative cooperation in the field of taxation.

A statutory audit is a legal requirement for many Cyprus companies. But for companies with proper accounting departments, international groups with Cyprus subsidiaries, and management teams that rely on accurate...

Switzerland remains one of the most attractive jurisdictions for internationally mobile individuals and families seeking political stability, personal security, a high quality of life and a reliable legal and tax environment.

The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.

There are a number of potential tax advantages when using FICs, including Inheritance Tax, but these will vary depending on the size

Tackling disguised remuneration (DR) has long been a focus for HMRC, and they have had significant success in the area, protecting billions of pounds of tax revenue.

A First-tier Tribunal has ruled that football referees engaged by Professional Game Match Officials Ltd were self-employed contractors rather than employees, rejecting HMRC's attempt to recover £584,000 in unpaid employment taxes.

Trustees and employers should assess how the Act will affect their scheme and start preparations now. While the government's indicative timeline suggests that most of the reforms will not come into force immediately...

Gelir İdaresi 2025 Yılı Vergi Harcamaları Raporunu yayınladı. 2025 yılında toplam 3 trilyon 170,3 milyar TL tutarında vergi harcaması gerçekleşti. En büyük pay 1.483,7 milyar ile gelir vergisinde oldu. Vergi harcamalarının GSYH'ye oranı %5,1 olarak hesaplandı.

Malta and Bulgaria have amended their double taxation treaty to align the Mutual Agreement Procedure with OECD standards, introducing a justification requirement that was conspicuously absent from the original text. While this change brings the treaty into conformity with international practice, the absence of mandatory arbitration provisions means taxpayers still lack a binding dispute resolution mechanism if competent authorities reach an impasse.

In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.