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UK Corporate Briefing Spring 2016 - Issue 5 - Spring 2016

Welcome to the spring 2016 edition of Dentons' UK Corporate Briefing, a quarterly summary of the most significant recent and forthcoming developments in company law and corporate finance regulation in the UK. Please see...more

Patent Box – Ultimi Aggiornamenti Dall’Agenzia Delle Entrate

As known the cd. "Patent Box" allows companies carrying out activities Research & Development to opt, as from the tax in 2015, for a taxation regime facilitated the income generated from the direct exploitation or indirect...more

Luxembourg tax reform 2017: key elements released

The Luxembourg government announced yesterday the key elements of a tax reform that should apply as from fiscal year 2017. Companies will generally benefit from a reduced corporate income tax rate, whilst minimum net wealth...more

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

Energy & commodities: portfolio acquisitions

There have been a number of trading portfolios acquired and disposed of in the commodities trading sector in the last 18 to 24 months (commodities acquisition(s)). This activity has been due to a number of factors, such as...more

European Commission Proposes Anti Tax Avoidance Directive - The proposed Council Directive is a further step towards tackling tax...

Background - The Commission has published a proposal for a Council Directive, the ‘Anti Tax Avoidance Directive’ (the “Proposed Directive”), confirming the Commission’s intention to combat tax avoidance and to coordinate...more

EU Anti-Tax Avoidance Directive Published: Implications For United Kingdom Corporate Taxpayers

On 28 January 2016 the EC published a proposal for a so-called Anti-Tax Avoidance Directive. If implemented it would apply to all taxpayers who are subject to corporate tax in an EU Member State, including corporate taxpayers...more

European Commission Publishes Anti Tax Avoidance Package

On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more

French Finance Act for 2016 and Amending Finance Act for 2015: The Most Important Changes Affecting Businesses

The French Finance Act for 2016 and Amending Finance Act for 2015 were enacted on December 30, 2015 (the “Acts”). Under the new legislation, the neutralization of the 5% add-backs on dividends within tax-consolidated groups...more

Tax Update: European Commission Decides Belgian Excess Profit Tax Rulings are Illegal State Aid - Granted to at Least 35...

On 11 January 2016, the European Commission decided that the tax adjustments granted under the Belgian tax scheme introduced in 2004 by Article 185 §2 of the Corporate Income Tax Code on excess profits within multinational...more

Implementation of EU P/S Directive GAAR; Dutch Decree regarding adaptation period for currently existing ATR's

Due to the adoption of the amended EU Parent-Subsidiary Directive into Dutch law, more specifically the EU Parent-Subsidiary Directive's general anti-abuse rule (GAAR), certain currently existing Advance Tax Rulings (ATRs)...more

Global Tax News - November 2015

HANDS OFF DIGITAL CURRENCIES! CANADA’S SENATE CALLS FOR A LIGHT REGULATORY APPROACH Formerly considered a gimmick for geeks and gamers, digital currencies, such as Bitcoin, have grown into a worldwide phenomenon...more

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and...more

EU Prohibits "Fiscal Aid"

The European Commission has ruled that two decisions made by national tax authorities artificially reduced the tax burden on the companies involved. ...more

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. ...more

Tax Policy Update

The number of “Action Items” detailed in the OECD’s report released yesterday to combat base erosion and profit shifting strategies among multinational corporations. The recommendations have drawn criticism from some GOP...more

Tax Policy Update

NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

Six Recommendations For Clients With Connections to France

There have been a number of changes to EU laws recently that have had, or will have, a direct impact on your clients who have connections with France. There are six stand-out issues that are worth careful and immediate...more

Corporate Alert: The Luxembourg Special Limited Partnership

Largely inspired by the Anglo-Saxon limited partnership regimes, the special limited partnership (SLP) has been designed to bolster Luxembourg’s position as the main alternative investment fund structuring hub in the EU at a...more

Tax Claim Opportunities for French Subsidiaries of MNEs

As a reminder, under French law, dividends received from resident or non-resident subsidiaries are 95% exempt at the French parent company’s level (the participation-exemption regime) provided certain conditions are met...more

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

Country-by-Country Reporting in the EU: Spain Adopts Regulations and the European Parliament Votes for Public Disclosure

On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect...more

The Devilish Details of the New Spanish Horizontal Tax Consolidation Regime

What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…). In June 2014, the European Court of Justice (ECJ) ruled that the...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

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