Corporate Taxes European Union Multinationals

News & Analysis as of

Brussels Tax Alert

A. Beneficial tax regime - Law 89/1967 "On the Establishment in Greece of Foreign Commercial and Industrial Companies" was meant to attract foreign investments in Greece, by providing a wide range of benefits regarding...more

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

Brexit: Keep Calm and Carry On?

Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more

Brexit: Key Tax Implications for Alternative Investment Funds and Investment Managers

The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more

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

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....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

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

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

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

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

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

Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

European Commission Launches Action Plan to Review EU Corporate Tax Framework and Close Tax Loopholes

The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more

Tax Policy Update

NUMBER OF THE WEEK: 61. The number of countries that have signed on to implement the OECD’s multilateral agreement for the automatic exchange of tax information, in conjunction with the ongoing Base Erosion and Profit...more

Orrick's Financial Industry Week in Review

European Commission Unveils Tax Transparency Package - The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national...more

European Commission Unveils Tax Transparency Package

The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national corporations. As of next year, EU members would have to declare their...more

EU Investigates Tax Rulings for Breach of State Aid Rules

The European Commission is currently conducting in-depth investigations into whether national tax rulings breach the EU’s competition rules. Whilst the spark for these investigations was the “Luxleaks” scandal, in December...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

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

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

Tax Measures in 2013 UK Budget

UK government supports businesses, focusing on the UK's competitiveness while clamping down on tax avoidance and evasion. On 20 March, UK Chancellor of the Exchequer George Osborne released the UK's 2013 budget. The...more

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