/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5ccaddd5abdfe8089c04fc6d/2019-09-07-19-46-47-978-5d7409278cb6230c1049789c.jpg)
Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...
Welcome to the European Tax Blog.
Some of Europe's brightest legal minds look at the tax issues across Europe which could impact multinational businesses.
“I see the 1.5% is being removed!” was the subject line of a client e-mail received early last Thursday afternoon in light of HMRC’s...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5cc833b7abdfe801f8b887af/2019-07-25-06-57-57-019-5d3952f5989b6e0dacc27f5c.jpg)
In the landmark Kühne & Heitz case, the Court of Justice held that an administrative body is – under certain conditions – obliged to...
If we imagine a Venn diagram of two overlapping circles, A and B, and call the overlapping area C, what can we say about the individual...
For UK tax practitioners who are feeling bereft after binge-watching the final season of Succession, the ongoing series of “unallowable...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5bade02498fcca12902fe597/2019-09-17-10-45-27-851-5d80b9478cb62309f8e0c406.jpg)
In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5dad74218cb623000828a1ec/2020-10-16-17-43-56-279-5f89dbdc8cb62a046c79fc71.jpg)
There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...
There are multiple purpose tests across different parts of the French corporate income tax legislation pursuant to which the French tax...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5bade02498fcca12902fe597/2019-04-25-16-20-56-821-5cc1de68989b6e0d381da8e0.jpg)
Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5bade02498fcca12902fe597/2019-04-25-16-21-11-759-5cc1de77abdfe90fa0ecd8c6.jpg)
Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...
In addition to the general anti-abuse rule (GAAR), numerous purpose tests are built into the UK tax code. Every time a new set of tax...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/617c127b49b23409885c6f85/2022-03-24-15-55-42-694-623c947ef636e915fc6a617b.jpg)
There are multiple purpose test provisions pursuant to which the Portuguese tax authorities can recharacterise or disregard a transaction...
The Spanish tax authorities can challenge transactions under purposes tests in the two different general anti-abuse rules (GAARs) as well...
/Passle/5cab65b0989b6e1650e15c51/MediaLibrary/Images/5bade02498fcca12902fe597/2019-04-25-16-21-24-834-5cc1de84abdfe90fa0ecd8d1.jpg)
Last week, HM Treasury released its Summary of Responses document to the consultation published earlier this year seeking views on the...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...