News & Analysis as of September 22, 2024

European Union › Income Taxes

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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 -

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on 5/31/2024

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

UK Tax Round Up - February 2024

Proskauer Rose LLP on 3/11/2024

Settlement payment subject to tax as employment income - In Mathur v HMRC, the Upper Tribunal (UT) has upheld the FTT’s decision that a £6 million settlement payment to a former employee following an employment tribunal...more

Establishing a Business Entity in Malta (Updated)

International Lawyers Network on 2/14/2024

Introduction - With its corporate laws based upon those of the UK, Malta has incorporated laws and principles into its own legislation, providing comfort and security to the commercial and business community. The most...more

New From January 2024 | Participation Exemption for European Corporations on Disposal of Shareholdings

McDermott Will & Emery on 11/28/2023

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

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on 10/20/2023

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

Draft Minimum Tax Directive Implementation Act: Minimum Taxation and Other Relevant Measures Legal Insights Germany

Morgan Lewis on 9/27/2023

On August 16, 2023, the German federal cabinet approved the government draft bill to implement Council Directive (EU) 2022/2523 to ensure global minimum taxation and further accompanying measures (Minimum Tax Directive...more

German Parliament Passes Law on Disclosure of Country-by-Country Income Tax Information LEGAL INSIGHTS GERMANY

Morgan Lewis on 6/2/2023

The German Parliament passed the law implementing Directive (EU) 2021/2101 with regard to the disclosure of income tax information by certain companies and branches (so-called public country-by-country reporting) on May 11,...more

Establishing A Business Entity In Lithuania (Updated)

International Lawyers Network on 3/10/2023

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

EU List of Non-Cooperative Jurisdictions Expanded

Cadwalader, Wickersham & Taft LLP on 2/28/2023

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

Taxation & Representation, Dec. 6, 2022

Brownstein Hyatt Farber Schreck on 12/8/2022

Legislative Lowdown - Last-Minute Attempt to Revive Permitting Legislation. According to sources familiar with the matter, several moderate lawmakers from both parties are pushing to include energy-permitting reform...more

UK Tax Round Up - October 2022

Proskauer Rose LLP on 11/1/2022

Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

UK Tax Round Up - September 2022

Proskauer Rose LLP on 9/30/2022

Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more

Temporary Solidarity Contribution concerning the Oil, Gas, Coal and Refinery Sectors

Hogan Lovells on 9/23/2022

The European Commission has published its proposal for a Council regulation on an emergency intervention to address high energy prices. Besides establishing a regime for demand reduction and a cap on market revenues from...more

EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit

Cadwalader, Wickersham & Taft LLP on 7/25/2022

In O. Fundusz lnwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”), Advocate-General Medina (the “AG”) of the Court of Justice of the European Union (“CJEU“) opined that the supply of...more

UK Tax Round Up - May 2022

Proskauer Rose LLP on 6/8/2022

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

EU Commission publishes draft directive to remove tax driven debt-equity bias

Proskauer - Tax Talks on 5/25/2022

Summary and Background - On 11 May 2022, the European Commission (the “Commission”) published its draft proposal for a debt-equity bias reduction allowance (“DEBRA” or, the “Directive”), which forms part of the...more

International News: Spotlight on Tax

McDermott Will & Emery on 5/5/2022

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

Establishing A Business Entity In Latvia (Updated)

International Lawyers Network on 2/22/2022

1. Types of Business Entities - Foreign investors may choose from the types of business entities: • Limited liability company • Joint stock company • Individual merchant • General partnership • Limited liability...more

Dechert Cyber Bits - Issue 7

Dechert LLP on 2/11/2022

EU Parliament Adopts Amended Digital Services Act by a Wide Margin - On January 21, 2022, the members of the EU Parliament approved by a large majority (77%) an amended draft of the Digital Services Act (“DSA”)....more

UK Tax Round Up - January 2022

Proskauer Rose LLP on 2/10/2022

UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Taxation & Representation, February 8, 2022

Brownstein Hyatt Farber Schreck on 2/9/2022

Legislative Lowdown - Build Back Better Reboot. Rep. Richard Neal (D-MA), the House Ways and Means Committee chair, and Sen. Ron Wyden (D-OR), chair of Senate Finance Committee, are cautiously optimistic negotiations over...more

Establishing a Business Entity in Estonia (Updated)

International Lawyers Network on 1/27/2022

1. Types of business entities - The most common types of companies in Estonia are the public limited liability company ("AS") and the private limited liability company ("OÜ"). The OÜ may be compared to a closed...more

ATAD2 – Reverse Hybrid Provisions enter into force 1 January 2022: What to do before year end!

Dechert LLP on 12/7/2021

While most of the European Anti-Hybrid Rules took effect on 1 January 2020, the last anti-hybrid provision – targeting the reverse hybrid mismatch – will enter into force in relevant EU jurisdictions (such as Luxembourg and...more

Partial Brexit? For income tax treaty purposes, US and UK competent authorities vote to remain

Eversheds Sutherland (US) LLP on 8/4/2021

While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the United Kingdom will remain in the EU for purposes of the US-UK Income Tax...more

New Developments on the VAT Exemption for Fund Management Services

Goodwin on 7/30/2021

On 17 June 2021, the Court of Justice of the European Union (CJEU) rendered two decisions about the application of the VAT exemption for management services provided in article 135 (1) (g) of the EU VAT Directive and...more

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European Union › Income Taxes

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