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
In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more
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
Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more
Mexico has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Relevant Features of the MLI - On March 15,...more
Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more
México suscribió el Convenio Multilateral para Implementar las Medidas Relacionadas con los Tratados Internacionales Destinadas a Prevenir la Erosión de las Bases Imponibles y el Traslado de Beneficios (Multilateral...more
The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more
More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. ...more
More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more
The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general...more
On May 31, 2021, Israel and the United Arab Emirates signed a tax treaty. This is the first tax treaty between the states. It is expected to go into effect on January 1, 2022, after passing the necessary ratification...more
On Monday, 31 May 2021, the UAE and Israel signed a tax treaty in order to boost economic cooperation. It is expected that, following ratification later this year, the treaty will come into effect on 1 January 2022. The move...more
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
From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD...more
Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more
The world’s most populous Spanish-speaking nation. Mexico is a Federation comprised of 32 states, being Mexico City the capital of the country. The government of Mexico is divided in three branches: the Legislative Branch in...more
The law of 20 June 2020 extended the measures concerning the holding of meetings in companies and other certain legal persons without the physical presence of the participants, initially provided for in the Grand Ducal...more
This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more
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
El 13 de diciembre de 2019 entró en vigor el Convenio para Evitar la Doble Tributación entre Colombia y el Reino Unido e Irlanda del Norte y su aplicación en materia de retenciones en la fuente será a partir del 1 de enero de...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