European Tax

In order to achieve consistency, any jurisdiction adopting the global minimum tax or “GloBE” rules has to follow the Model Rules and the...

This post provides an overview of the Spanish legal framework applicable to the use of carried forward tax losses (NOLs) and briefly...

The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares...

At a webinar on 18 January, the OECD presented its findings on the impact of international tax reform in advance of the full report which...

In our previous posts on the recently approved Law to foster Spain’s start-up ecosystem (here and here), we focused on...

The French National Financial Prosecutor’s Office (Parquet National Financier - PNF) published new Guidelines on public interest judicial...

For the second year running, the OECD provided an update on the two-pillared international tax reform project just days before Christmas....

Draft legislation for the Electricity Generator Levy (EGL) was published on 20 December 2022 for inclusion in the Spring Finance Bill. It...

You may recall that back in that glorious summer of 2021, when the pandemic restrictions were beginning to be lifted, we tried to entice...

The Council of the European Union issued a press release on Tuesday, stating that negotiators representing the European Parliament and...

Under the current legislation, Italy taxes non-resident entities only on capital gains derived from a direct sale of Italian immovable...

On 1 December 2022, the new so-called “Start-up Law” was passed by the Spanish Parliament. The Law aims to foster the start-up ecosystem...

In September 2022, Brazil and the UK announced a first round of negotiations for a double taxation agreement (DTA) following several...

The Spanish Government recently published a proposal to tax non-Spanish-tax-resident individuals who hold Spanish real estate through one...

In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage...

In what is thankfully an unusual occurrence in legal practice, I was about to press send on an email advising a client on an issue (in...