Regulatory Blog

On 8 October 2024, the EU updated the list of non-cooperative tax jurisdictions, removing Antigua and Barbuda from Annex I (the blacklist) after a supplementary review by the Global Forum on Tax Transparency and Exchange of Information for Tax Purposes. However, the country remains on Annex II (a watchlist) pending further improvements in tax transparency.

On 26 September 2024, the Court of Justice of the European Union issued its judgement in case C-432/23 in which it reinforced the principle of client-attorney privilege in the context of the exchange of information with the tax administration, limiting the extent to which lawyers can be compelled to disclose confidential client information under the Administrative Cooperation Directive (Directive 2011/16), commonly referred to as DAC.

On 10 September 2024, the Court of Justice of the European Union upheld the European Commission’s decision in 2016 that Ireland granted unlawful tax advantages to Apple, amounting to €13 billion. This judgement overturns the earlier 2020 decision by the General Court, which had annulled the findings of the European Commission due to insufficient evidence of selective advantage.

On 8 July 2024, the Cyprus Tax Department issued Circular 4/2024 which provides clarifications on the 50 per cent income tax exemption for employment exercised in Cyprus, as outlined in section 8(23A) of the Income Tax Law of 2002, as amended. The latest amendments were introduced on 30 June 2023 and apply retrospectively as of 1 January 2022.

The British Virgin Islands Beneficial Ownership Secure Search System Act has been amended by the Beneficial Ownership Secure Search System (Amendment) Act, 2024, which was published in the Gazette on 24 July 2024.

On 17 July 2024, draft legislation No. 8414 was proposed to the Luxembourg Parliament, introducing new tax measures aimed to improve Luxembourg's competitiveness and appeal to businesses, investors, and foreign talent.

On 12 June 2024, Luxembourg's government submitted a new bill to Parliament, aiming to amend and complete the Luxembourg law of 22 December 2023 implementing the Pillar Two Directive on minimum taxation.

On 23 May 2024, the Luxembourg Government introduced a bill of law before the Luxembourg Parliament aiming notably to clarify the tax treatment applicable to share class redemptions.

On 14 May 2024, after years of discussion, the EU Council reached a general agreement on its draft proposal of the Faster and Safer Relief of Excess Withholding Taxes (FASTER) directive. This proposal aims to establish faster and less burdensome withholding tax relief procedures. At the same time Member State authorities may exclude relief request from FASTER’s fast track procedure for further investigation, where deemed necessary to mitigate the risks of tax abusive.