Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
On May 14, 2024, ECOFIN agreed on the Directive on Faster and Safer Relief of Excess Withholding Taxes (so-called FASTER Directive) after numerous adjustments to the EU Commission's proposal for a directive from June last...more
Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more
In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to UK...more
El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more
One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more
The European Commission has launched a public consultation on its proposal to introduce a new common EU-wide system for withholding tax on dividend or interest payments. The consultation period will end on 26 June 2022....more
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
Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more
In data 22 dicembre 2021, la Commissione Europea ha adottato una Proposta di Direttiva finalizzata a contrastare l’uso improprio ai fini fiscali delle società di comodo residenti nei paesi dell’Unione (“Proposal for a Council...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
ASIC has released its third quarter update on corporate finance regulatory activities. From an M&A perspective, the update includes ASIC's observations on its public M&A deal statistics, outlines ASIC's recent concerns in M&A...more
On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more
The United Kingdom (U.K.) currently operates certain off-payroll working rules (commonly referred to as IR35), which subject certain individuals (often operating as consultants to businesses) working through intermediaries...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
For months now the treatment of licence fee income generated in Germany under licence agreements concluded between foreign companies where the right granted is merely listed in a public register in Germany has been causing...more
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
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
Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more
On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more
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
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
The Singaporean response to the COVID-19 outbreak has been comprehensive and coordinated. The 18 February 2020 "Unity Budget" introduced a raft of measures designed to help protect jobs and businesses from the economic...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