In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more
A draft European Union ("EU") Directive tackling the use of shell entities for tax purposes is currently being negotiated, with potential corrective measures to be considered. ...more
The Situation: In December 2020, the French administrative supreme court issued a major decision expanding the permanent establishment ("PE") concept and criteria for both French corporate income tax ("CIT") and value-added...more
Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more
The Situation: The Netherlands has 79 bilateral investment treaties ("BITs") in place with non-EU countries. On March 22, 2019, the Dutch government published a new model BIT ("2019 Model") as a template for negotiating new...more
7/25/2019
/ Arbitration ,
Bilateral Investment Treaties ,
Corporate Social Responsibility ,
Foreign Investment ,
ICSID ,
International Arbitration ,
Investor Protection ,
Investor State Dispute Settlement (ISDS) ,
Investors ,
Netherlands ,
UNCITRAL
The Situation: The Member States of the EU have unanimously agreed on a proposed directive establishing new and far-reaching tax reporting obligations for "intermediaries" and taxpayers.
The Result: The proposal lays down...more
For the benefit of our clients and friends investing in European distressed opportunities, our European Network is sharing some current developments...more
3/28/2017
/ Anti-Corruption ,
Avoidance ,
BaFin ,
Corporate Taxes ,
Creditors ,
Cross-Border ,
Debtors ,
EU ,
Foreign Investment ,
France ,
Germany ,
Insolvency ,
Italy ,
Netting Agreements ,
Sapin II