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Anti-Avoidance Corporate Taxes

International Lawyers Network

Establishing a Business Entity in Romania (Updated)

1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more

Proskauer Rose LLP

UK Tax Round Up - January 2024

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Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

Blake, Cassels & Graydon LLP

Propositions législatives du 4 août 2023 : Présentation de certaines mesures fiscales

Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more

Blake, Cassels & Graydon LLP

2023 August 4 Draft Legislation: Selected Tax Measures

On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more

International Lawyers Network

Establishing A Business Entity In Romania (Updated)

1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more

Holland & Knight LLP

2023 Mexican Tax Considerations for Mexican and Foreign Taxpayers

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Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more

White & Case LLP

ATAD III: Is the tide turning on shell companies?

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The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Katten Muchin Rosenman LLP

New Rate of Stamp Duty Land Tax (SDLT) for Non-UK Residents

Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more

Proskauer Rose LLP

UK Tax Round Up - April 2020

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Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

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On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

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UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

Proskauer Rose LLP

UK Tax Round Up - July 2019

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Finance Bill 2019-2020 - The FB19-20 was published on 11 July. The majority of the matters included have been announced previously with no surprise measures. The draft legislation is now open for consultation. We have...more

Proskauer Rose LLP

UK Tax Round Up - May 2019

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UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

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Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

White & Case LLP

New Polish Tax Reforms Bring Much-Needed Structural Certainty Allowing Direct Issuances by Polish Issuers

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European Leveraged Finance Alert Series: Issue 1, 2019 - New Polish laws, effective 1 January 2019, have reformed the tax treatment of a number of different taxable business activities. In particular, the Ministry of...more

Latham & Watkins LLP

2019 - A Year of Change for UK Corporate Tax?

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The UK government broadens the scope of tax on non-resident persons and contemplates changes to stamp duty, taxing the digital economy, and Brexit-related changes. In recent years the pace of change in the corporate tax...more

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more

Womble Bond Dickinson

International Tax Policy Top 10 Timeline: The Events in Europe in the First Half of 2019 That Will Impact the Taxation of US...

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A number of tax and political milestones in 2019 will directly and indirectly impact the ongoing global initiative to develop new rules for taxing the activities of cross-border business. The headline international tax...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2018 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

Bracewell LLP

Bracewell Tax Report - September 2018 #2

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Jones Day

Treasury Provides Details on Transition Tax

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Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more

Proskauer Rose LLP

UK Tax Round Up - May 2018

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General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

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General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

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