Corporate Taxes, EU, Subsidiaries

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

Goodwin on 1/18/2021

On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more

EU General Court strikes a blow to Commission approach to fiscal State aids in the Apple tax case

White & Case LLP on 7/20/2020

The General Court has upheld a challenge to a 2016 Commission decision that had required Ireland to recover €13.2 billion in illegal State aid from Apple, on account of alleged preferential tax treatment for the...more

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

Akin Gump Strauss Hauer & Feld LLP on 6/27/2016

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,...

Nutter McClennen & Fish LLP on 6/27/2016

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

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on 7/15/2015

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

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

K&L Gates LLP on 8/5/2014

On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more