By Davide Anghileri, University of Lausanne, Switzerland
On 4 October, the EU Code of Conduct Group (Business Taxation) published a report recommending that the EU Council amend the EU list of non-cooperative tax jurisdictions by removing the United Arab Emirates and the Marshall Islands.
The changes to the list follow the efforts made by the two jurisdictions to meet legal requirements for all entities to locally maintain “economic substance” in line with the level and type of activity they undertake.
As a consequence, the UAE would be removed from annex I (blacklist), while the Marshall Islands would be moved from annex I of the conclusions to annex II (grey list), which includes jurisdictions that have undertaken sufficient commitments to reform their tax policies.
Moreover, the Code of Conduct Group suggested removing from the annex II grey list the following countries: Albania, Costa Rica, Mauritius, Serbia, and Switzerland, as they were found compliant with all commitments on tax cooperation.
The EU Council is expected to adopt an update to the EU list of non-cooperative jurisdictions without discussion during its meeting on 10 October.
Davide Anghileri
Davide Anghileri is a PhD candidate at the University of Lausanne, where he is writing his thesis on the attribution of profits to PEs. He researches transfer pricing issues and lectures for the Master of Advanced Studies in International Taxation and Executive Program on Transfer Pricing.
Anghileri, a Contributing Editor at MNE Tax, previously worked as a policy advisor to the Swiss government on BEPS issues.
Davide can be reached at [email protected].
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