The Italian government recently approved a draft 2024 budget law which provides for the extension of the domestic participation exemption regime on disposal of shareholdings (PEX) to those non-resident corporations that: (i)...more
11/28/2023
/ Corporate Entities ,
Corporate Taxes ,
EU ,
European Economic Area (EEA) ,
Income Taxes ,
Italy ,
Legislative Agendas ,
Member State ,
New Legislation ,
New Regulations ,
New Rules ,
Regulatory Agenda ,
Shareholders ,
Tax Code ,
TIEA
On October 16, 2023, the Council of Ministers approved, in preliminary examination, the draft of a legislative decree implementing the tax reform on international taxation. The draft decree must now acquire the opinions of...more
The Judgement -
In its judgment no. 21261 issued on 19 July, the Italian Supreme Court stated that non-resident companies without an Italian permanent establishment (PE) are entitled to apply the Italian 95% participation...more
EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE -
On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more
6/6/2022
/ American Bar Association (ABA) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Taxes ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
EU ,
European Commission ,
GILTI tax ,
Investigations ,
Member State ,
Model Rules ,
OECD ,
Pillar 2 ,
Sustainability ,
Tax Rates ,
White Collar Crimes
INTRODUCTION TO US TAXATION OF NFTS -
Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more
WHAT IS THE AIM OF PILLAR 2 RULES?
The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Frameworkâs project is to ensure that multinational groups of companies pay a minimum level of tax...more
On 26 February 2019, the Court of Justice of the European Union (CJEU) issued long-awaited judgments in a group of cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more
On February 26, 2019 the Court of Justice of the European Union (CJEU) issued the long-awaited judgments on the cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more
3/5/2019
/ Anti-Abuse Rule ,
Beneficial Owner ,
Court of Justice of the European Union (CJEU) ,
Dividends ,
EU ,
Member State ,
OECD ,
Parent Corporation ,
Payment Services Directive ,
Subsidiaries ,
Tax Exemptions ,
Withholding Tax