Regulatory Blog

The BVI International Tax Authority recently hosted a Common Reporting Standards webinar, introducing substantial updates to CRS compliance and upcoming regulatory requirements for financial institutions. These changes, coupled with key filing deadlines for 2025, highlight the heightened focus on regulatory compliance within the BVI.

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.

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.

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.