Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
THE WONDER YEARS WEBINAR
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more
The Judgement - In its judgment no. 21261 issued on 19 July, the Italian Supreme Court stated that non-resident companies without an Italian permanent establishment (PE) are entitled to apply the Italian 95% participation...more
On 14 February 2023, the Council of the European Union approved adding Russia to the EU list of non-cooperative jurisdictions for tax purposes (the "EU List") (official publication on 21 February 2023)....more
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more
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
In his address to the nation on 25 March 2020, the Russian President requested the government to implement measures ensuring the adequate taxation of Russian-sourced dividend and interest payments to "offshore" jurisdictions....more
The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more
The UK House of Commons has rejected the government’s proposed Withdrawal Agreement. Unless the Agreement (or an amended version of it) is approved by the House of Commons, or the Brexit date of 29 March 2019 is postponed or...more
ALFI Notes the Commission’s Plans to Amend the UCITS and AIFM Directives - ALFI issued a press release pointing out that they believe that a wider scope for the clarification of marketing and pre-marketing would have been...more
On March 21, 2018, the European Commission released a draft legislative package for “fair taxation of the digital economy,” which would establish new tax rules for digital business activities within the European Union. This...more
International investment funds are set to benefit from measures issued by the Bank of Italy, aimed at facilitating direct investment into the country by EU alternative investment funds....more
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
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
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more
On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports...more
Germany provides insight into its tax treaty negotiation policy. The German Federal Ministry of Finance has followed the lead of the United States, Austria and Belgium and has published a model double tax treaty for...more