News & Analysis as of

Luxembourg draft budget for 2015 submitted to Parliament

On 15 October 2014, the Luxembourg Minister of Finance submitted the draft budget for 2015 (the Budget Bill) to the Parliament. The Budget Bill does not overhaul the Luxembourg corporate tax environment, however, it proposes...more

Bank Julius Baer Customer Implicated in Alleged Tax Fraud

Reuters is reporting that Bank Julius Baer is cooperating with French authorities in their criminal investigation into an alleged value-added-tax (“VAT”) fraud in the EU Emissions Trading System. ...more

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

VAT Alert: Cross-Border Supplies Of Services Made To VAT Grouped Branches: Skandia America Corp. (USA), filial Sverige (C-7/13)

For VAT purposes, a supply of services from the headquarters of a company to its branch is generally not subject to VAT. This is well-established, and was confirmed in the Court of Justice of the European Union (the "Court of...more

Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union

On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of...more

Monitoring recent Swiss tax developments: key takeaways

In the realm of multinational corporate tax planning, Switzerland has long been a key jurisdiction due to its generally attractive business attributes (solid infrastructure and multilingual, skilled workforce) and competitive...more

Increase of ratio of film support

On 24 June 2014 the European Commission resolved that it does not object to an increase in indirect state support (in the form of a tax rebate), from 20% to 25%, for the production costs of films produced in Hungary. It is...more

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

Sweden proposes new system for corporate taxation: a redistribution of tax payments in the business sector

A Swedish government committee mandated to analyze the Swedish corporate tax system - including the need for a more comprehensive approach to the overall deductibility of interest expenses, as well as the strengthening of the...more

European Court of Justice judgment on the exemption of foreign investment funds from CIT in Poland

The European Court of Justice has issued a judgment concerning the authority of Poland to grant a corporate income tax (CIT) exemption to investment funds depending on where their registered offices are located. Polish...more

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

International Tax News - March 2014

NETHERLANDS: TAX TREATMENT OF HYBRID FINANCE INSTRUMENTS IN THE WAKE OF TWO LANDMARK CASES - The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance...more

Spain amends tax treatment of debt restructuring

As a result of a substantial reform of the Insolvency Law, starting January 1, 2014 the tax treatment of debt restructuring modifies both Spain's Corporate Income Tax Law and its stamp duty regulations....more

Update: EU VAT on E-Commerce

There are a great variety of electronically provided services (“e-services”) and the respective market is rapidly growing. The general definition is that e-services are services which are delivered over the Internet or an...more

Enactment of the French Finance Act for 2014 and Amending Finance Act for 2013: Key Corporation Tax Measures

The French Finance Act for 2014 and Amending Finance Act for 2013 were adopted by the French Parliament on December 19, 2013 and were enacted on December 30, 2013 [the “Acts”]. The core objectives of the Acts are to return...more

Domestic double taxation relief applicable to capital gains derived by EU resident entities on disposal of shares in Spanish...

Following the non-discrimination principle, in response to an appeal dated 25 Octobe the Spanish Supreme Court has applied a tax credit to avoid double taxation, provided in the Corporate Income Tax Law for Spanish resident...more

New changes in real estate taxation

The French Amended Finance Act for 2013 and the Finance Act for 2014, both dated 29 December 2013, have been adopted and entered into force on 31 December 2013. Some of their provisions bring again new changes on real estate...more

Gaming Legal News - November 2013 • Volume 6, Number 25: Investment – Why Bulgaria?

The strategic geographical position of the country and the membership with the European Union provide a wide range of investment opportunities in Bulgaria not only for local, but for foreign investors as well. The advanced...more

Transfer Pricing: Major Developments for Certain French Companies Engaging in Transactions with Related Entities

The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies. New Provisions of French Law - Provisions Already Adopted - Within the...more

Corporate tax reform is coming to Switzerland

Tax experts in Switzerland now predict that certain Swiss tax regimes – the cantonal tax regime, the holding regime and, in particular, the auxiliary company regime, will ultimately need to be repealed. A repeal of...more

Shale Gas Exploration

The UK Government has proposed that the tax rate on certain profits from UK shale gas production should be reduced from 62% to 30%. This will make the UK’s shale gas tax rate among the lowest in the world....more

International Tax News - September 2013

FRANCE ANNOUNCES DRAFT 2014 BUDGET – LIGHTER TAX BURDEN FOR BUSINESSES - France’s draft budget law for 2014 was presented to Parliament on September 25 and is now under discussion in the National Assembly and...more

OECD issues White Paper on transfer pricing documentation: new requirements for multinationals coming in 2014?

The OECD has issued the “White Paper on Transfer Pricing Documentation” outlining ideas for new global standards for the annual transfer pricing documentation exercise required by more than 60 countries. ...more

The Cyprus crisis and its international tax regime: what multinationals should know

Cyprus has been a member of the European Union since 2004. The country has long been known for its low corporate income tax rate and absence of withholding taxes on payments of interest, dividends and royalties paid to...more

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