European Union: Tax Treaties

The European Commission has unveiled its most comprehensive EU direct tax framework review to date, shifting policy focus from anti-avoidance measures toward competitiveness and simplification. The Tax Simplification Package promises EUR8 billion in annual savings through sweeping changes to withholding taxes, dividend taxation, interest limitation rules, and cross-border structures. These reforms will fundamentally reshape how businesses structure their European operations, requiring careful analysis of ex

Malta's Individual Tax Programme consolidates special tax status for international residents, retirees and UN pensioners from January 2027, offering a 15% rate on qualifying foreign income received in Malta. With minimum annual tax ranging from €15,000 to €35,000 depending on category, the programme requires qualifying property, medical insurance and compliance with specific eligibility conditions across four distinct resident categories.

Through Legal Notice 97 of 2026, Malta introduced amendments to the Double Taxation Relief on Taxes on Income with Romania Order.

Le Tribunal administratif de Strasbourg examine un litige fiscal portant sur une convention de centralisation de trésorerie (cash pool) entre une société française et une entité suédoise liée.

The European Commission's DAC Recast proposal introduces sweeping changes to cross-border tax reporting obligations, including a significant carve-out for multinational groups subject to Pillar Two's 15% minimum tax rate. With the removal of generic Category A hallmarks and extended reporting deadlines, the reforms promise over €1 billion in annual compliance savings while maintaining robust anti-avoidance protections. How will these targeted simplifications reshape the landscape of mandatory disclosu

The European Commission has proposed a comprehensive recast of the Directive on Administrative Cooperation, consolidating DAC1 through DAC9 into a single legal framework. This legislative initiative aims to streamline and strengthen the EU's administrative cooperation mechanisms in direct taxation, with significant implications for compliance frameworks across member states.

Poland's tax system imposes mandatory costs and contribution burdens that compound over time, with an exit tax that becomes more expensive the longer entrepreneurs wait to act. For those who have built valuable businesses, Cyprus offers a compelling alternative with 0% tax on dividends for Non-Dom residents, 15% corporate tax, and a straightforward EU relocation process that includes English-speaking professionals and 300 days of sunshine.

Malta and Bulgaria have amended their double taxation treaty to align the Mutual Agreement Procedure with OECD standards, introducing a justification requirement that was conspicuously absent from the original text. While this change brings the treaty into conformity with international practice, the absence of mandatory arbitration provisions means taxpayers still lack a binding dispute resolution mechanism if competent authorities reach an impasse.

La Cour administrative d'appel de Paris examine le cas d'un non-résident ayant exercé des stock-options en France puis cédé les actions à perte. La question centrale porte sur la possibilité de déduire cette moins-value de cession...