On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more
Takeaways -
The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace.
The U.S., U.K. and...more
Takeaways
- While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK.
- That is actually a good thing in one respect: UK...more
The European Union (EU)-U.K. Trade and Cooperation Agreement (TCA) governing post-Brexit trade relations between the U.K. and the EU includes provisions regulating EU/U.K. antitrust enforcement and cooperation effective...more
1/14/2021
/ Antitrust Provisions ,
Cartels ,
Competition ,
EU ,
International Tax Issues ,
Member State ,
Merger Controls ,
State Aid ,
UK ,
UK Brexit ,
UK Competition and Markets Authority (CMA) ,
Withdrawal Agreement
Fund sponsors, investment advisors and other financial market participants would be forgiven for not concerning themselves with tax initiatives originally targeted at the digital economy. However, with the latest technical...more
In this series, “Critical Thinking in the Time of COVID-19,” our European tax practice examines the next stage of analysis for corporates that have begun digesting the economic and legal impact of COVID-19 on their...more
4/6/2020
/ Compliance ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
France ,
Germany ,
International Tax Issues ,
Lobbying ,
Social Insurance Contributions ,
State Aid ,
UK
In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more
1/28/2020
/ BEPS ,
Corporate Taxes ,
Cross-Border Transactions ,
Due Diligence ,
EBITDA ,
Financing ,
International Tax Issues ,
Multinationals ,
Risk Assessment ,
Risk Management ,
Tax Planning ,
Tax Treaty ,
Transfer Pricing
Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more
1/23/2018
/ Corporate Taxes ,
Digital Assets ,
EU ,
European Commission ,
France ,
International Tax Issues ,
Italy ,
Multinationals ,
OECD ,
State Aid ,
Tax Reform ,
UK
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
2/6/2017
/ Anti Tax Avoidance Directive (ATAD) ,
BEPS ,
Business Taxes ,
Corporate Taxes ,
Cross-Border Transactions ,
EBITDA ,
EU ,
Exports ,
Foreign Acquisitions ,
Foreign Subsidiaries ,
Imports ,
International Tax Issues ,
Inversion ,
Mergers ,
Multinationals ,
OECD ,
Parent Corporation ,
State Aid ,
Tax Reform ,
Trump Administration ,
UK Brexit
On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more
6/28/2016
/ Anti-Avoidance ,
Article 50 Treaty of the EU ,
Bilateral Agreements ,
Conflicts of Laws ,
Corporate Taxes ,
Data Protection ,
David Cameron ,
Debt Financing ,
Dispute Resolution ,
EU ,
EU Data Protection Laws ,
European Economic Area (EEA) ,
Financial Services Industry ,
Free Movement ,
Global Economy ,
Hague Convention ,
Immigration ,
International Arbitration ,
International Labor Laws ,
International Tax Issues ,
Referendums ,
Scotland ,
Stamp Duty Land Tax ,
State Aid ,
Treaty of Lisbon ,
UK ,
UK Brexit ,
UK Competition and Markets Authority (CMA) ,
Value-Added Tax (VAT) ,
Withholding Tax ,
WTO
As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account...more