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Corporate Taxes European Union Controlled Foreign Corporations

White & Case LLP

ATAD III: Is the tide turning on shell companies?

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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

Hogan Lovells

Impact of the new Spanish CFC rules on controlled foreign holding companies

Hogan Lovells on

The new Spanish Controlled Foreign Company rules might have a major impact on non-resident holding companies, and particularly those resident in a country outside the EU and the EEA due to the controversial (and, in our view,...more

Bilzin Sumberg

Looking for a GILTI-Free Structure? Try Estonia

Bilzin Sumberg on

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

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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

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

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

Jones Day

Japan Legal Update - Volume 39 | August 2018

Jones Day on

Japan Signs Economic Partnership Agreement with EU - On July 17, 2018, Japan signed an Economic Partnership Agreement ("Japan-EU EPA") with the European Union ("EU"). Once the Japan-EU EPA is implemented, 99 percent of EU...more

BCLP

EU & Competition Law Update – November 2017

BCLP on

EU opens investigation into UK tax scheme for multinationals - The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal...more

Skadden, Arps, Slate, Meagher & Flom LLP

European Commission Opens State Aid Investigation Into Finance Company Exemption From UK CFC Rules

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

Dechert LLP

Brexit – The UK and International Tax Consequences

Dechert LLP on

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Nutter McClennen & Fish LLP

Amid the Economic Uncertainties of the Brexit, New Challenges in Corporate Tax Structuring for UK Companies (And Their Parents,...

The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more

BakerHostetler

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

BakerHostetler on

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

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