By Davide Anghileri, University of Lausanne, Switzerland
On 4 November, the EU Code of Conduct Group (Business Taxation) released a report recommending that the EU Council amend the EU list of non-cooperative tax jurisdictions by removing Belize from annex I (blacklist) and the Republic of North Macedonia from annex II (grey list).
Belize adopted on 11 October a reform of its International Business Companies (IBC regime) that could be considered not harmful. As a result, in the opinion of the Code of Conduct Group, Belize could be removed from annex I. However, the Code of Conduct Group recommends maintaining Belize in annex II pending implementation of its commitment to amend or abolish the harmful features of its foreign source income exemption regime.
On the other hand, the Code of Conduct Group suggests removing the Republic of North Macedonia from the grey list due to its ratification of the OECD Multilateral Convention on Mutual Administrative Assistance (MAC). The instrument of ratification was deposited with the Council of Europe on 30 September and the MAC will enter into force for the Republic of North Macedonia on 1 January 2020.
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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