BEPS

PE risk for French banking & insurance activities: time to get it right!

Luxembourg and France have been very closely linked for centuries. So, it’s only natural that the French market is crucial for Luxembourg banks and insurance companies in terms of local sales activities. As wealth planning solutions in particular require a close presence to clients, most Luxembourg banks and insurance companies sell their services on French […]

Are you impacted by the new transfer pricing guidelines on financial transactions?

Background On 11 February 2020, the Organization for Economic Co-operation and Development (OECD) published its final guidelines on financial transactions as part of a newly added Chapter X. The first draft was published on 7 September 2018 in light of the 2015 report on BEPS Actions 8-10, which mandated follow-up to the transfer pricing aspects of financial […]
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How BEPS 2.0 unified approach will revolutionize business models

With its new proposal (published October 9), the OECD tries to answer one burning question: How can profits and corresponding taxing rights on cross-border activities performed by multinationals be (re)allocated to cope with the ever-changing business models of the 21st century? The OECD’s objective is to build a consensus by the end of 2020 on interna […]
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BEPS 2.0: The corporate tax revolution for international business is here!

The last few years have seen some big changes in the corporate tax world – from ATAD1 & 2 and the EU Commission’s anti-tax avoidance package to the recent US tax reform. The impact of these new rules has not gone unnoticed in many countries now subject to significant changes, and often harsher tax principles. This is just a drop in the ocean, howeve […]
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Mandatory Disclosure Rules: five key questions for insurers

The Mandatory Disclosure Rules (MDR) arose from the ambitious anti-tax avoidance project on Base Erosion and Profit Shifting (BEPS) that the OECD launched in 2015. The MDR Directive, also known as DAC 6, is the latest EU initiative regarding the automatic exchange of tax information. Aimed at identifying harmful tax practices and further increasing tax transp […]

New, ethical Luxembourg–Senegal double tax treaty means opportunity

On 10 February 2016, Luxembourg and Senegal reinforced their co-operation on an international level by signing a double tax treaty. Entering into force on 14 June 2018, and applicable from 1 January 2019, the treaty differs greatly to previous treaties between Luxembourg and African countries in that it is the first one to include specific guidance and provision […]
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