On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more
A recent debtor-friendly Indonesian Constitutional Court decision (putusan) raises uncertainty as to a creditor's right to exercise its self-help remedy (parate executie) in respect of assets subject to fiducia security....more
A mental image of a building sprouting wings and taking to the sky is one way to picture a flying freehold, but mention the phrase to most property lawyers and their hearts will sink. Discovering a flying freehold raises...more
The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
Appraisal has long been utilized as a tool for resolution of disputes over the amount of loss at issue in property insurance claims. Appraisal was once an amicable, prompt and independent process to resolve claims when...more
On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The legislation will come...more