Issue 68 - November 2023
The recently proposed EU BEFIT directive is an ambitious initiative to introduce a common set of rules for EU-based groups of companies and head offices to determine their taxable base. BEFIT aims to simplify the tax rules, reduce compliance costs and ensure a fairer allocation of taxing rights among EU member states, but it could create challenges for business groups operating in the EU that may undermine the proposal’s effectiveness and feasibility. Our first lead article looks at how the proposal could actually introduce more complexity and uncertainty.
India’s Supreme Court has ruled that benefits under a most favored nation (MFN) clause in India’s tax treaties are not triggered automatically and the Indian tax authorities must issue a notification to give effect to an MFN clause. The decision will impact all taxpayers that have claimed benefits under an MFN clause, either in the form of concessional tax rates or where a restricted scope is adopted and it’s possible that the Indian tax authorities may open past matters based on the decision.
Learn about these developments and more in Corporate Tax News and be sure to explore our new Pillar Two implementation column where we consolidate updates relating to the introduction of a global minimum tax.