Corporate Taxes, EU, Foreign Subsidiaries

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

Hogan Lovells on 10/20/2021

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

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

McDermott Will & Emery on 2/11/2020

The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

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

Womble Bond Dickinson on 2/13/2019

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

UK Tax Round Up - May 2018

Proskauer Rose LLP on 5/31/2018

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

EU & Competition Law Update – November 2017

BCLP on 11/20/2017

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

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

Skadden, Arps, Slate, Meagher & Flom LLP on 10/31/2017

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

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

Skadden, Arps, Slate, Meagher & Flom LLP on 2/6/2017

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

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