Regulatory Blog

During the last G7 summit a "side-by-side" system was proposed to address concerns raised by the United States regarding Pillar 2.

On 24 June 2025, a decision by the Judicial Committee of the Privy Council overturned Jersey’s first-ever declaration of incompatibility under the Human Rights (Jersey) Law 2000 in a case that focussed on the International Co-operation (Protection from Liability) (Jersey) Law 2018, which limits costs and damages against public authorities acting in good faith to fulfil international requests.

On 10 April 2025, the House of Representatives of Cyprus (HoR) approved amendments in Cyprus tax legislation focusing on corporation practices in low-tax jurisdictions (LTJs) and EU "blacklisted" jurisdictions (BLJs).

On 14 April 2025, the European Council adopted another amendment to the Directive on administrative cooperation in the field of taxation, extending exchange of information and cooperation into the Pillar 2 area.

On 3 April 2025, the Court of Justice of the European Union delivered a significant judgment in C-228/24 Nordcurrent, offering critical guidance on the interpretation of the anti-abuse provisions under the Parent-Subsidiary Directive. This decision has far-reaching implications for businesses operating cross-border structures within the EU.

On 29 January 2025, Luxembourg’s tax authority published Circular L.I.R. n° 164/1, replacing the guidelines issued in 1998. This development modernises the rules for determining interest rates applicable to shareholder current accounts, introducing critical changes grounded in the arm’s length principle.

On 17 February 2025, the Government of Bermuda released its third consultation paper on the Corporate Income Tax Act 2023, focussing on provisions to ensure the effective administration of the CIT Act. This follows a careful review of feedback from the first two consultations, further refining the proposals to strike a balance between ease of administration and taxpayer compliance costs and robust tax collection and liability determination mechanisms. The consultation closes on 10 March 2025, and stakeholders are invited to submit their comments and suggestions via email.

On 12 December 2024, the Cyprus House of Representatives approved the implementation of a global minimum tax law in Cyprus for multinational enterprise groups and large domestic groups, aligning with the EU Pillar Two Directive 2022/2523. The GMT Law establishes a minimum effective tax rate of 15 per cent for MNEs with annual consolidated revenues exceeding €750 million. The GMT Law is currently in force as it was published in the Official Gazette of the Republic of Cyprus on 18 December 2024.

The seminar hosted by the Cayman Islands Compliance Association and the Department for International Tax Cooperation in November 2024, provided important updates and valuable insights into the Cayman Islands’ tax transparency initiatives, compliance priorities and regulatory developments.

Recent judgments from the Court of Justice of the European Union (CJEU) and the Luxembourg District Court have clarified VAT obligations for Luxembourg board members.

On 11 December 2024, Luxembourg’s Parliament approved a series of tax measures aimed at supporting individuals and boosting the attractiveness of businesses. These changes, effective from tax years 2024 or 2025 depending on the provision, focus on reducing corporate tax burdens, updating rules, and aligning with international standards.

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.