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
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
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
Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more
KEY POINTS - The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes. - The Legal Professional Privilege exemption is still unclear. - Penalties have been capped at £5,000. ...more
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more
Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more
We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more
A number of tax and political milestones in 2019 will directly and indirectly impact the ongoing global initiative to develop new rules for taxing the activities of cross-border business. The headline international tax...more
General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more
On October 26, 2017, the European Commission (EC) announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group...more
General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more
International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more
We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more
How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more
Welcome to the Winter edition of Real World from Dechert’s London Finance and Real Estate Group, keeping you up to date with recent developments in real estate law and practice. In this issue: - An A-Z for 2013 – A...more