In any event, even under current law, the unified exemption amount will automatically decrease to $5 million (plus an inflation adjustment) come January 1, 2026.
Against this backdrop, the Middle Eastern economies are battling lower oil prices and budget deficits, which in turn increase the pressure for fiscal receipts.
The Supreme Court, in its judgment, found that the legal concept of ‘estoppel by convention’ applied in this case.
The Luxembourg Court has also issued several decisions, which addressed challenges by the Luxembourg tax authorities of periods following the entry into force as of 1 January 2015 of the formal ruling procedure.
This includes employees and directors who are posted or made available as part of an intra-group transfer, for instance, from a foreign parent company to a subsidiary based in France.