News & Analysis as of September 24, 2024

European Union › Capital Gains

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The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -

Italian 2024 budget law - Allen & Overy

A&O Shearman on 1/18/2024

The Budget Law extends the applicability of the Italian participation exemption regime (Italian PEX) to companies and trade entities which are resident in an EU or EEA member State (that allows an adequate exchange of...more

UK Tax Round Up - May 2023

Proskauer Rose LLP on 6/6/2023

Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more

Withholding tax exemption on dividends and capital gains for non-resident investment funds

Hogan Lovells on 1/18/2021

The 2021 Italian Budget Law aligns the tax treatment applicable to EU investment funds with the tax treatment applicable to Italian investment funds....more

French Withholding Tax on Capital Gains Realized on Substantial Shareholdings by Non-French Companies Ruled Illegal

McDermott Will & Emery on 12/15/2020

The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more

Possible Tax Exemption for EU Investment Funds Investing into Italy – Update from the Draft Tax Bill for 2021

McDermott Will & Emery on 11/30/2020

There has been some important news to come out of the preliminary drafts of the Italian Tax Bill for financial year (FY) 2021, which may have a very significant–and positive–impact on the asset management industry and in...more

Update on the Enforcement and Litigation Issues Arising out of Cum-Ex Trades

Cohen & Gresser LLP on 12/10/2019

The shock waves from the German authorities’ tax evasion investigation into cum-ex transactions, a complex form of dividend arbitrage, continue to be felt throughout Europe. A large number of UK and European financial...more

UK Tax Round Up - April 2019

Proskauer Rose LLP on 5/2/2019

UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Spring Funds First Update

BCLP on 2/28/2019

Welcome to our Funds First Update. Whilst a lot of focus at present is on Brexit and the uncertainties surrounding that process, there have been a great many other developments in the past few months that are of relevance to...more

Investment Funds Update – Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on 2/4/2019

Money Market Funds - The AMF published a guide describing the main impacts of the application of the MMF Regulation, as well as the details of the authorization procedures specific to such money market funds, notably...more

UK Tax Round Up - March 2018

Proskauer Rose LLP on 4/5/2018

Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more

Tax Round Up - June 2017

Proskauer Rose LLP on 6/16/2017

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

U.S.-India Newsletter - Vol. 2016, Issue 3

Troutman Pepper on 10/6/2016

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Indian Government Approves New India-Cyprus Tax Treaty

Perkins Coie on 8/26/2016

The Indian government approved a new India-Cyprus tax treaty on August 24, 2016 that will allow the Indian government to tax capital gains on investments routed through Cyprus. This is part of a continuing campaign by the...more

Private equity in Italy: market and regulatory overview

Latham & Watkins LLP on 6/2/2016

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Skadden, Arps, Slate, Meagher & Flom LLP on 1/22/2016

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Six Recommendations For Clients With Connections to France

McDermott Will & Emery on 9/28/2015

There have been a number of changes to EU laws recently that have had, or will have, a direct impact on your clients who have connections with France. There are six stand-out issues that are worth careful and immediate...more

Starting a Hedge Fund in 2015

Dechert LLP on 3/18/2015

Hedge funds are well into the transition from bastions of alternative investment to being accepted into the mainstream investment marketplace. It is now estimated that global hedge fund assets under management amount to in...more

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

Dechert LLP on 3/27/2014

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

Sale of dividend claims to third parties by non-resident taxpayers

Latham & Watkins LLP on 12/20/2013

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

Capital Gains Tax on U.K. Property for Non-Residents

Akin Gump Strauss Hauer & Feld LLP on 11/22/2013

According to various reports, the Chancellor of the Exchequer is considering announcing in his Autumn Statement in December that capital gains tax (“CGT”) will be imposed on non-U.K. resident property sellers for the first...more

"Shares for Rights: Over-Sold or Under-Appreciated?"

Skadden, Arps, Slate, Meagher & Flom LLP on 5/14/2013

In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more

Overriding Interest - Spring 2013

K&L Gates LLP on 4/24/2013

In this issue: - The Green Deal - Impact on Commercial Real Estate - High Value Residential Property Tax - Announcements and Events - Transaction Profile - Focus on Henderson Global Investors ...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

K&L Gates LLP on 4/2/2013

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

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European Union › Capital Gains

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