News - 13.03.2024

Focus on International Tax

  • The Financial Centre

“Over the past two decades, we have seen an acceleration in cooperation between states to fundamentally change the international tax environment, and this has already produced tangible results”, noted Manal Corwin, during her keynote address at our recent Focus On livestream dedicated to international taxation. The Director of the OECD Centre for Tax Policy and Administration recalled the progress made in cross-border information exchange, the widespread adoption of the BEPS (Base Erosion and Profit Shifting) project in 2015 and the gradual introduction of the Two-Pillar Solution for the taxation of multinational companies.

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For Thierry Lesage, Partner at Arendt & Medernach, the reason why the OECD felt it was necessary to develop the Two-Pillar Solution, which provides for the taxation of multinationals in the countries where they do business on the one hand, and a minimum tax rate of 15% on the other, is that “the BEPS project did not go far enough”. However, as Elisabeth Adam, partner at Elvinger Hoss Prussen, pointed out, other projects are also on the European Commission’s drawing board, some of which are struggling to come to fruition. This is the case with the draft of ATAD 3 (Anti-Tax Avoidance Directive), which has been under discussion for 2 years, and the DAC 6 Directive (A directive pertaining to cross-border tax arrangements), which has been subject to various legal challenges.

Favourable taxation has also generally been introduced in a number of places to attract new economic players to a country. Can it have the same effect on attracting talent? Keith O’Donnell, managing partner of Atoz Tax Advisors Luxembourg, is cautious on this question: “Taxation will never be a sufficient criterion; to attract talent you need a package of measures that can include taxation but also quality of life.”

View the full replay here.