Baker McKenzie Tax

#ClientAlert On 11 December 2024, the State Secretariat for International Financial Matters announced changes to the taxation of dividends due to the repeal of the application of the most-favored-nation clause in the double taxation avoidance agreement between Switzerland and India of 2 November 1994, as amended. As a result, from 1 January 2025, the residual withholding tax for dividend distributions by a Swiss company to its Indian parent will again increase from 5% to 10%. Dividend distributions from Switzerland to India will, however, still be able to benefit from this clause until 31 December 2024. Nothing changes for dividend distributions from India to Switzerland. Read about the details and what needs to be considered in the analysis of Baker McKenzie Switzerland partners Susanne Liebel-Kotz and Philippe Reich: https://lnkd.in/dPTt__Rr #BakerMcKenzie #BakerMcKenzieSwitzerland #taxfromeveryangle #trade #Switzerland #India

In an important milestone for its Tax Reform, Brazil's National Congress approved the basic text of the Complementary Bill (PLP 68/24) that regulates Constitutional Amendment 132/23 and institutes the Tax on Goods and Services (IBS), the Social Contribution on Goods and Services (CBS), the Selective Tax (IS) and creates the IBS Management Committee. Final text is expected to be enacted by the President by the end of the week, before parliamentary recess. Read the detailed legal alert published by Trench Rossi Watanabe - with whom we have executed a strategic cooperation agreement for consulting on Brazilian law. https://lnkd.in/dk6DXJed #taxreform #tax #Brazil

Overview for Private Equity executives - multi-jurisdictional international carried interest tax reforms. This alert delves into specific developments in the United States of America, the United Kingdom, The Netherlands, Spain, Belgium, Germany, France, Switzerland and Luxembourg, providing a comparative analysis of how each jurisdiction is addressing the issue. Read here to find out what you need to be aware of: https://lnkd.in/eF6D48dS #taxfromeveryangle #carriedinterest #privateequity

Abe Zhao Senior Tax Consulting Director at Baker McKenzie FenXun, authored an article published in the International Tax Review. In the article, Abe analyzed a recent case involving a High and New Technology Enterprise (HNTE) and examined how China’s tax authorities have heightened their scrutiny of intercompany transactions through transfer pricing (TP) audits.   Read more: https://lnkd.in/eX9VfFg5 #BakerMcKenzieTax #Transferpricingaudits #China  

VAT Deduction? The CJEU's preliminary ruling states that VAT deduction is allowed on equipment that is provided for free when linked to taxable activities. Read more on this ruling here https://lnkd.in/eZGRPTtS Philipp Stanek | Olivier Van Baelen | Nienke van Etten #bakermckenzietax #taxfromeveryangle #indirecttax

We are excited to share that Bloomberg has published an insightful article delving into the implications of the OECD's Pillar Two on Brazil and Colombia, exploring how these countries are navigating the introduction of domestic minimum top-up taxes. The piece is authored by Clarissa Giannetti Machado Miras (Trench Rossi Watanabe*) and Ciro Meza (Baker McKenzie Colombia). 🔗 Read the article here: https://lnkd.in/gavJsWb8 #Tax #OECD #PillarTwo #Brazil #Colombia #BloombergTax #TrenchRossi #BakerMcKenzieLatAm *Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement to consult on foreign law.

📢 New webinar series Debt and equity capital market transactions are an important financing tool for listed companies globally and in Switzerland — and they almost always raise tax issues.   In Baker McKenzie Switzerland's new #webinar series "Taxes in Capital Markets Transactions," our lawyers discuss various aspects of tax in this context. What needs to be considered before, during and after the transaction tax-wise? What is particularly important to know in Switzerland — or particularly different compared to other countries? In Module 1, Susanne Liebel-Kotz and Andrea B. Bolliger look into capital increases, including an overview of basics, reorganization exemption and restructuring. You can register for the webinar series here: https://lnkd.in/dnARngaZ Our webinar modules are short and concise and focus on the important aspects of taxes in Swiss capital market transactions. #BakerMcKenzieSwitzerland #taxfromeveryangle #capitalmarkets #transactions #debt #equity #tax 

Multinational groups, with annual revenue exceeding EUR 750m (c. AED 3 billion) in two of the last four financial years, will be subject to the UAE's Domestic Minimum Top Up Tax. Whilst the specific legislation is yet to be released, we understand from the UAE Ministry of Finance's press release that the legislative framework will be in line with the OECD's GloBE Model Rules.    As part of introducing a Domestic Minimum Top Up Tax, the UAE has announced the introduction of a Research and Development tax incentive (expected to commence from 1 January 2026) and a refundable tax credit for high-value employment activities that are located in the UAE (expected to commence from 1 January 2025).   A more detailed news alert will be published following the release of the legislation. Please reach out to our tax team and Pillar two experts Reggie Mezu and Ben Phillips for more details. #corporatetax #Pillar2 #UAE Baker McKenzie Tax

BAKER MCKENZIE WINTER TAX UPDATE 2025 ❄️ As we reflect on a dynamic 2024, marked by significant developments at the OECD, EU, and domestic levels, we invite you to join us for our 3rd Annual Baker McKenzie Winter Tax Update on January 23, 2025, at 5:45 PM. This event will provide a comprehensive overview of the latest tax trends and their implications for businesses operating in Luxembourg! 📅 Agenda: 5:30 pm: Registration and welcome 5:45 pm: Conference - Legal developments on the tax treatment of share buy-back and Luxembourg participation exemption - what’s new? - Pillar 2 implementation - where do we stand in Luxembourg and what can we expect from the OECD, the EU and the USA? - A Luxembourg reform to boost Luxembourg’s attractiveness and retain employees - how can you benefit from it? - Unshell, New DACs, ATAD directives, FASTER, ViDA, etc. - what has been approved in 2024, not yet approved or could be amended in 2025? Tax litigation - what are the recent developments, at legislative, tax authorities and courts level? - Luxembourg case law - What can we learn from recent tax decisions (e.g. abuse of law, requalification of debt instruments into equity, VAT and director fees)? ... and much more! 7:15 pm: Networking cocktail We look forward to meeting you at our premises:   📍  Baker McKenzie Luxembourg 10-12 Bd Franklin Delano Roosevelt, 2450 Luxembourg   🔗 Register now: https://lnkd.in/enat_jtk Antonio Alvarado Weffer Diogo Duarte de Oliveira Amar Hamouche Olivier Dal Farra Baker McKenzie Luxembourg Baker McKenzie Baker McKenzie Tax #BakerMcKenzie #WinterTaxUpdate #TaxTrends #LuxembourgTax #OECD #EU #TaxImplications #Business #Finance #TaxLaw

On 4 December 2024, the Dutch Ministry of Finance published the 27 November 2024 Decree No. 2024-0000528135 ("Amount B Decree 2025"), outlining the Netherlands' position on the application of the OECD IF's Pillar One Amount B as of 1 January 2025. Based on the Amount B Decree 2025, Amount B will not be introduced for Dutch taxpayers, but it may become relevant for taxpayers with baseline marketing and distribution activities in covered jurisdictions. Read our client alert: https://lnkd.in/ejpDAtAK Imke Gerdes (she/her) | Hub Stolker | Alejandro Z. | Yannick Scholte Baker McKenzie Amsterdam #AmountB #Netherlands #BakerMcKenzieTax