News & Analysis as of September 20, 2024

European Union › International Tax Issues

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The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -

'FASTER" EU Council of Ministers Adopts Directive to Harmonize Withholding Tax Procedures

Morgan Lewis on 6/27/2024

On May 14, 2024, ECOFIN agreed on the Directive on Faster and Safer Relief of Excess Withholding Taxes (so-called FASTER Directive) after numerous adjustments to the EU Commission's proposal for a directive from June last...more

Economic Substance Regime Overview

Conyers on 6/4/2024

The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on 5/31/2024

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Europe Daily News, 19 March 2024

Mayer Brown on 3/19/2024

COMPETITION - Non-opposition to a notified concentration (Case M.11409 - Elia / Glentra / Energyre / Energyre Giga Projects USA) - Non-opposition to a notified concentration (Case M.11475 - Mitsui / Osaka Gas / RWE KK /...more

Amount B or not to be? The OECD’s Pillar One Amount B report

A&O Shearman on 3/1/2024

The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

Guiding Captives Through Global Developments

Conyers on 2/21/2024

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

British Virgin Islands Removed from EU Tax Blacklist

Conyers on 11/3/2023

Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on 10/20/2023

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

New Multilateral Tax Treaty Implements the Subject to Tax Rule

Holland & Knight LLP on 10/5/2023

More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Draft Minimum Tax Directive Implementation Act: Minimum Taxation and Other Relevant Measures Legal Insights Germany

Morgan Lewis on 9/27/2023

On August 16, 2023, the German federal cabinet approved the government draft bill to implement Council Directive (EU) 2022/2523 to ensure global minimum taxation and further accompanying measures (Minimum Tax Directive...more

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on 8/9/2023

This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

Telework from abroad: tax consequences for employers?

Ius Laboris on 8/1/2023

As employers face growing calls to allow employees to ‘work from anywhere’, they should also consider the possible tax consequences of inadvertently creating a permanent establishment in another country. But what counts as...more

Will Unshell be washed away? An uncertain future for ATAD 3 - the EU’s tax proposal on shell entities

A&O Shearman on 7/14/2023

The European Commission put forward a proposal in 2021 to tackle shell entities (known as ATAD 3). Despite widespread support for the concept, reaching agreement on the technical details of the Unshell Directive has proved...more

New tax obligations for platform operators as Spain transposes DAC7

Hogan Lovells on 6/14/2023

Pursuant to the transposition in Spain of the Council Directive (EU) 2021/514 of 22 March 2021 (so-called “DAC7”) and the implementation of the Model Rules for Reporting by Platform Operators developed by the OECD/G20 BEPS...more

Doing business in Italy 2023

Hogan Lovells on 5/30/2023

This booklet has been written specifically for business individuals and whilst it may be of interest to their local advisers, such as lawyers or accountants, the information is intended for a wider audience. We cover topics...more

EU List of Non-Cooperative Jurisdictions Expanded

Cadwalader, Wickersham & Taft LLP on 2/28/2023

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

European Court Expands Legal Professional Privilege in the EU

Wilson Sonsini Goodrich & Rosati on 1/5/2023

In a recent judgment, the European Court of Justice (ECJ) expanded the scope of Legal Professional Privilege (LPP) in the EU, recognizing that it is not limited to advice given for the purpose of defense but covers all...more

UK VAT Treatment of Fund Management Review Announced

Cadwalader, Wickersham & Taft LLP on 12/19/2022

As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...more

EU Court of Justice Faults European Commission for Expansive Interpretation of State Aid in Tax Rulings

Skadden, Arps, Slate, Meagher & Flom LLP on 12/1/2022

On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more

Getting the Fiats Straight: CJEU Annulled State Aid Decision against Fiat

Cadwalader, Wickersham & Taft LLP on 11/30/2022

On 8 November 2022, the Court of Justice of the European Union (the “CJEU”) set aside the EU General Court’s judgment of 2019 and annulled the European Commission’s State aid decision of 2015, which held that Luxembourg...more

Sub-Participations Are VAT Exempt Under EU Law

Cadwalader, Wickersham & Taft LLP on 10/20/2022

The Court of Justice of the European Union (the “CJEU”) held on 6 October 2022 in O. Fundusz lnwestycyjny zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”) that the supply of services provided by a...more

ATAD 3 or the importance of adequate substance

Hogan Lovells on 8/9/2022

At its dawn, the ATAD 3 Proposal and its adverse tax consequences were considered by some as the demise of international investment and holding structures. Others pointed out the uncertainties surrounding key terms related to...more

A New Direction for ATAD III Proposal?

Goodwin on 8/4/2022

Further to the request of the European Parliament for concerted EU action, the European Commission issued on 22 December 2021 a proposal for a Council Directive laying down rules to prevent the misuse of shell entities...more

EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit

Cadwalader, Wickersham & Taft LLP on 7/25/2022

In O. Fundusz lnwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”), Advocate-General Medina (the “AG”) of the Court of Justice of the European Union (“CJEU“) opined that the supply of...more

European Commission Consultation on EU-wide Withholding Tax System

Cadwalader, Wickersham & Taft LLP on 6/24/2022

The European Commission has launched a public consultation on its proposal to introduce a new common EU-wide system for withholding tax on dividend or interest payments. The consultation period will end on 26 June 2022....more

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European Union › International Tax Issues

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