Foreign investment funds may be eligible for Dutch dividend withholding tax refunds
The Dutch Supreme Court decided in the Köln Aktienfonds Deka (KA DEKA) case that foreign investment funds are eligible for a refund of...
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The discrimination introduced by the non-French resident capital gains tax is not covered by the EU standstill clause: timing is of the essence!
The Administrative Court of Appeal of Versailles has recently ruled that the capital gains tax charge applicable to non-residents on the...
Italian “mixed takeover bids" are not tax neutral
In principle, a “takeover bid” means a public purchase offer, whether mandatory or voluntary, made to the holders of securities in a...
How Brexit might limit challenges to HMRC decisions
Looking at the CJEU decision in Luxembourg v B in the context of the UK's proposed new Financial Institution Notice (which would...
Main highlights of 2021 Spanish tax reforms
Shortly after the approval of the new Financial Transaction Tax and Digital Services Tax, the Spanish Government has submitted to...
Spanish scrip dividends: Let the shareholder decide!
In the last years, scrip dividends had become a very popular equity remuneration scheme for Spanish listed companies, as it helped them...
IP taxation: German nexus in unexpected circumstances
The German Ministry of Finance (BMF) published the first guidance on one of the most hotly discussed German tax issues of the year on...
The Spanish Supreme Court stands as the latest pacta sunt servanda watch
The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the...
Argentina: new reporting regime for domestic and international tax planning arrangements
The Argentine Tax Authority (AFIP) published a broadly drafted mandatory reporting regime for domestic and international tax planning...
Virtual currencies: what's in a name?
Spend too long thinking about the virtual or digital world in opposition to the "real" world, and it's almost guaranteed you'll start...
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