The EU’s 14th “package” of sanctions against Russia introduces anti-circumvention measures targeting the non-EU subsidiaries of EU entities and creates new restrictions, including on LNG. This Client Alert is published in...more
Despite significant political headwinds, particularly from the United States, Canada’s digital services tax (DST) was enacted pursuant to an order-in-council dated June 28, 2024. The DST is an annual 3% tax on digital...more
The Chancellor of the Exchequer delivered the United Kingdom (UK) Spring Budget for 2024 on 8 March 2024. The Budget was delivered against the backdrop of an anticipated general election in the summer or autumn of 2024 and...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
Section 3(a)(5) of the Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”) defines a “dealer” as “any person engaged in the business of buying and selling securities […] for such person’s own account...more
Davies’ Canadian Mergers & Acquisitions guide draws on our substantial cross-border M&A experience to offer guidance on both the legal framework and practical aspects of Canadian mergers and acquisitions, including critical...more
Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more
On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more
Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more
The Department of Finance (Canada) (Finance) has released revised draft legislation on the proposed rules regarding excessive interest and financing expenses limitation (EIFEL). The revised draft legislation, released on...more
On June 23, 2022, the Canadian Parliament passed legislation implementing changes that significantly expand the scope of the Canadian Competition Act....more
Significant amendments to Canada’s Competition Act (Act) were enacted on June 23, 2022, with the passing of the federal government’s 2022 budget implementation legislation. The amendments foreshadow more aggressive...more
Following previously adopted restrictions on payments of dividends in joint stock companies, Decree No. 254 requires that any dividend payment from a limited liability company to its foreign participant connected with an...more
President Vladimir Putin issued a decree introducing a special procedure for repayment of debt by the Russian state bodies as well as Russian residents (Russian Debtors) to non-Russian creditors related to foreign states that...more
The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more
The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more
Like a classic Shakespearean drama, the IR35 story is both long and complicated. Act III is due to start, again, on 6 April 2021. Once more unto the breach, dear friends, once more....more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
The Supreme Court of Canada heard one appeal in January and will hear seven more in February and March that may interest the business community or organizations facing civil litigation...more
Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more
Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more
Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more