{"id":29538,"date":"2025-09-16T14:58:31","date_gmt":"2025-09-16T12:58:31","guid":{"rendered":"https:\/\/it.andersen.com\/?p=29538"},"modified":"2025-09-19T16:19:09","modified_gmt":"2025-09-19T14:19:09","slug":"step-in-tax-the-international-tax-newsletter","status":"publish","type":"post","link":"https:\/\/it.andersen.com\/en\/step-in-tax-the-international-tax-newsletter\/","title":{"rendered":"Step in Tax – The International Tax Newsletter"},"content":{"rendered":"

International taxation is constantly evolving, and for companies operating in Europe it is crucial to have a clear and up-to-date vision in order to make informed strategic decisions.<\/strong>
To address this need, Andersen launches Step in Tax<\/em>, the European newsletter on international taxation that provides practical insights and analysis on the latest developments in the tax landscape.<\/p>\n

What is Step in Tax?<\/h2>\n

The newsletter offers updates on national and EU legislation, OECD initiatives, and recent court rulings, with a particular focus on cross-border challenges that may impact corporate strategies.<\/p>\n

Key topics covered in the first issue:<\/strong><\/p>\n

New HMRC powers in the UK on DAOs and offshore structures<\/h3>\n

The UK is introducing new powers for HM Revenue & Customs (HMRC) with the inclusion of section 148A TIOPA 2010, effective from 2026. This provision will allow entities that are not formally connected\u2014such as Cayman foundation companies and decentralised autonomous organisations (DAOs)\u2014to be treated as related parties, based on economic substance rather than legal form. This marks a significant shift in transfer pricing, expanding the scope of tax audits to structures that until now were often outside the radar.<\/p>\n

CJEU ruling in the Nordcurrent case: economic substance and impact on UK companies<\/h3>\n

In the Nordcurrent<\/em> case, the Court of Justice of the European Union underlined that the lack of genuine economic substance in UK companies may jeopardize the application of tax exemptions under the Parent-Subsidiary Directive. The ruling stressed the importance of having a real and substantial presence in the territory to avoid being classified as artificial arrangements. This issue is particularly relevant given that the UK does not impose formal substance requirements, unlike other jurisdictions.<\/p>\n

Decision on the deductibility of Royalty Withholding Tax in Ireland<\/h3>\n

A recent decision by the Irish Tax Appeals Commission confirmed that Royalty Withholding Tax (RWHT) paid abroad may be considered a deductible business expense for tax purposes, at least for fiscal periods prior to 2020. The Commission held that this tax, although a tax on income, constitutes a \u201cnecessary and unavoidable\u201d cost of doing business and therefore meets the deductibility criteria under the law.<\/p>\n

Tax reform proposals in Cyprus: support for families and businesses<\/h3>\n

The Cypriot government has introduced proposals aimed at reducing the tax burden on families and businesses, in line with its goal of modernizing the tax system and strengthening economic resilience. Key measures include:<\/p>\n

    \n
  • \n

    Raising the personal income tax exemption threshold from \u20ac19,500 to \u20ac20,500<\/p>\n<\/li>\n

  • \n

    Applying the top tax rate of 35% only to income above \u20ac80,000<\/p>\n<\/li>\n

  • \n

    Increasing the corporate tax rate (CIT) from 12.5% to 15%<\/p>\n<\/li>\n

  • \n

    Reducing dividend distribution tax from 17% to 5%<\/p>\n<\/li>\n

  • \n

    Granting tax exemption for reinvested profits<\/p>\n<\/li>\n

  • \n

    Introducing family tax deductions and abolishing the defense contribution on rental income<\/p>\n<\/li>\n<\/ul>\n

    Reclassification of interest-free loans as equity in Luxembourg<\/h3>\n

    The Luxembourg Administrative Court confirmed the reclassification of interest-free shareholder loans as hidden capital contributions, reaffirming the principle of substance over form. The ruling emphasized that tax qualification must be based on the true economic nature of the transaction rather than its legal structure. Furthermore, the decision highlighted the limits of administrative practice 85\/15 on debt-to-equity ratios, treating it as a guiding but non-binding criterion.<\/p>\n

    Belgian case law on tax abuse and beneficial ownership in the Interest and Royalties Directive<\/h3>\n

    Recent Belgian case law clarified that the withholding tax exemption under the Interest and Royalties Directive may also apply to the legal owner of the interest received, not just the ultimate beneficial owner (UBO). The Belgian court further ruled out the existence of tax abuse where genuine business activities and adequate tax substance are present, thereby confirming the protection of the principle of legitimate expectations for economic operators.<\/p>\n","protected":false},"excerpt":{"rendered":"

    International taxation is constantly evolving, and for companies operating in Europe it is crucial to have a clear and up-to-date vision in order to make informed strategic decisions.To address this need, Andersen launches Step in Tax, the European newsletter on international taxation that provides practical insights and analysis on the latest developments in the tax […]<\/p>\n","protected":false},"author":125,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[50],"tags":[],"_links":{"self":[{"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/posts\/29538"}],"collection":[{"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/users\/125"}],"replies":[{"embeddable":true,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/comments?post=29538"}],"version-history":[{"count":1,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/posts\/29538\/revisions"}],"predecessor-version":[{"id":29539,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/posts\/29538\/revisions\/29539"}],"wp:attachment":[{"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/media?parent=29538"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/categories?post=29538"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/it.andersen.com\/en\/wp-json\/wp\/v2\/tags?post=29538"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}