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Corporate Taxes European Union

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Trends in cross-border real estate investment and the changing tax landscape

by Hogan Lovells on

Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

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

European Court of Justice rules Belgian fairness tax in breach of the Parent Subsidiary Directive

by DLA Piper on

The European Court of Justice (ECJ) has ruled that the Belgian fairness tax violates the Parent-Subsidiary Directive in certain specific circumstances. This decision may be the latest step leading to the annulment of the tax,...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

by Hogan Lovells on

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

EuroResource—Deals & Debt - March 2017

by Jones Day on

For the benefit of our clients and friends investing in European distressed opportunities, our European Network is sharing some current developments...more

German Corporate Law Update: Important Changes in Acquisitions and Investments

For companies interested in investing in, purchasing or selling German companies, here are several recent developments related to Data Privacy and Cybersecurity, M&A, Employment and Tax law that are helpful to keep in mind....more

Ten things to consider when you do a leveraged finance deal in Germany

by White & Case LLP on

European Leveraged Finance Alert Series: Issue 2 - As forecasted in our 30 January 2017 publication "European leveraged debt fights back," we expect 2017 to be a year where high yield bonds and covenant light "term loan...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

German tax law changes and their impact on multinationals

by DLA Piper on

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

New tax measures approved in Spain

by DLA Piper on

The Council of Ministers has approved Royal Decree-law 3/2016, of 2 December, that introduces different measures in order to comply with the objectives established by the European Union in the Council Recommendation of 21...more

"Double Trouble": The Kenyan Constitution and DTAs

by Dentons on

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

Recent EU and Luxembourg anti-BEPS developments extending to third countries

by DLA Piper on

EU Commission's ATAD proposal released On 25 October 2016 the EU Commission presented yet another package of corporate tax reforms comprising, inter alia, a proposal on tackling "hybrid mismatches" between the tax...more

European Commission publishes an EU corporate tax system

by DLA Piper on

Today the European Commission published three corporate tax directives that potentially will apply in 27 Member States (28 - UK) of the European Union. These corporate tax directives include: the Common Consolidated Tax Base...more

Brexit: An Opportunity to Readjust UK Tax Policy?

The U.K. government mantra has for a number of years been: "Britain is open for business." This has been reflected in a number of areas relevant to U.K. domestic and foreign tax policy, including in a gradual reduction of the...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

by Latham & Watkins LLP on

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Digesting the €13 Billion Apple-EU Tax Ruling

by King & Spalding on

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

by Latham & Watkins LLP on

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

State aid – the European Commission charges forward

by DLA Piper on

This note provides an update on the EU state aid decisions and aims to put recent developments in context. We review the current state of the state aid investigations, provide some political context, touch on the US...more

Implications of the UK’s Brexit Referendum

by Ropes & Gray LLP on

As autumn approaches and preparation for the next round of Brexit discussions begins, this note summarises the current position and analysis following the UK’s vote to leave the EU on the 23rd June (the “Referendum”). Whilst...more

EU tax ruling levies €13 billion state aid penalty on Apple

by King & Spalding on

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

Withholding Tax Contrary to EU Law: The Brisal Case

On 13 July, the Court of Justice of the European Union (CJEU) released its decision in the Brisal case (C-18/15). The Brisal case has potentially far reaching implications for European Union (EU) businesses that either...more

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