Cum/ex schemes: ESMA recommendations
The European Securities and Markets Authority (ESMA) has recommended legislative change to enable National Competent Authorities (NCAs)...
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Colombian beneficial ownership concept: Unsolved questions
The 2019 Colombian tax reform introduced a new definition of beneficial owner for tax purposes. But the result may be an increase in...
Highlights from the 2021 Dutch Budget
The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate...
Spanish courts adhere to Danish conduit cases
When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court (
Buyer beware!
Indemnity payments under a share purchase agreement are taxable in the hands of the purchaser, irrespective of their accounting...
New Dutch position on Brazilian interest on net equity is contestable
On 28 August 2020, the Dutch State Secretary of Finance issued a policy decision (the "Decision") on the treatment of the juros sobre o...
Break fees and VAT
HMRC had for some time taken a somewhat arbitrary position in relation to the VAT liability of payments made by a party terminating a...
India's Transparent Taxation initiative: the angel (if any) will be in the detail
On 13 August 2020, the Prime Minister of India announced a number of steps to make the Indian tax system "seamless, faceless and...
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