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Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
On 31 January 2022, the UAE Ministry of Finance announced the introduction of Federal Corporate Tax (CT) in UAE w.e.f. 1 June 2023.
Guidance on the tax rules affecting investment funds and fund managers.
1. Persons covered All residents in the UAE or Israel, including foreign national individuals and companies, can benefit from the DTT. A resident in one of the contracting states may be exempted from income tax or obtain a credit equal to the income tax paid with respect to income derived and taxed in the other contracting state. 2. Residents With regard to the UAE, the DTT defines a resident as: (1) an individual who is present in the UAE for a period, or periods, amounting to 183 days or more in the tax year concerned and the previous tax year; (2) a qualified government entity or corpora...
Luxembourg has introduced new legislation [1] disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European Union list of non-cooperative jurisdictions for tax purposes. This new provision applies as of 1 March 2021. Below is a summary of the main points covered by this law: SCOPE OF THE LAW The deduction of interest or royalties owed by Luxembourg corporate taxpayers is denied when the beneficiary of the interest or royalties meets all the following conditions: The...