4/29/2021 12:00:00 AM Japan and Spain update their double taxation treaty: no withholding on dividends, interest and royalties By Carlos García-Olías Santiago Tórtola Japan and Spain have signed a new tax treaty in connection with income taxes and to prevent tax evasion and avoidance (the “Treaty”). The...
4/19/2021 12:00:00 AM German RETT reform finally close to implementation in July 2021 By Sebastian Heinrichs The reform of the German Real Estate Transfer Tax (RETT) Act took a decisive step towards implementation. Since the RETT reform focuses...
4/16/2021 12:00:00 AM The long-awaited Euromoney decision has finally appeared. But is it right? By William Watson For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test....
4/12/2021 8:43:16 AM Taxing Tokens By Slaughter and May The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad...
4/10/2021 8:32:16 AM Amsterdam Appeal Court: what are the limits to using post-dated OECD commentaries in interpreting a double tax treaty? By Maarten van der Weijden The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of...
4/9/2021 10:49:08 AM French Administrative Supreme Court takes post-dated OECD commentaries into consideration in interpreting French-Irish double tax treaty By Yves Rutschmann Victor Camatta In its decision in the Valueclick Case on 11 December 2020, the French Administrative Supreme Court ruled on the existence of a permanent...
4/8/2021 1:05:58 PM To what extent can post-dated OECD commentaries be taken into account in interpreting a double tax treaty? By Maarten van der Weijden Yves Rutschmann Victor Camatta This question - which is of utmost importance as the OECD commentaries provide key insights to tax authorities, taxpayers and judges, on...
4/7/2021 10:24:18 AM The Netherlands proposes new legislation to deal with asymmetrical transfer pricing adjustments By Paul Sleurink On 4 March 2021, the Dutch government presented a draft bill for comments by interested parties introducing fundamental changes to Dutch...
4/6/2021 12:00:00 AM The Spanish Supreme Court confirms that non-Spanish sovereign wealth funds may be fully exempt from tax on Spanish source dividends By Blanca García On 24 February 2021, the Spanish Supreme Court handed down a significant ruling which prohibits differences in tax treatment between...