1/31/2023 1:11:17 PM New limitation on the offsetting of tax losses generated in 2023 by entities taxed under the Spanish CIT consolidation regime By Álvaro García Ferriz María González Cuervo This post provides an overview of the Spanish legal framework applicable to the use of carried forward tax losses (NOLs) and briefly...
1/26/2023 11:07:56 AM Share deals in peril of double taxation under new RETT law By Gunther Wagner The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares...
1/20/2023 2:32:26 PM International tax reform – now more worth the effort? By Zoe Andrews 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...
1/17/2023 4:59:23 PM Thinking of setting up a business in Spain? Take a look at the new tax incentives for start-ups By Alex Pié Alberto Artamendi Gutiérrez In our previous posts on the recently approved Law to foster Spain’s start-up ecosystem (here and here), we focused on tempting expats...
1/17/2023 11:17:14 AM French National Financial Prosecutor’s Office releases new guidelines for implementing public interest judicial agreements By Guillaume Pellegrin Yves Rutschmann Arnaud Mailhos The French National Financial Prosecutor’s Office (Parquet National Financier - PNF) published new Guidelines on public interest judicial...
1/10/2023 2:43:25 PM Digital Services Taxes: draft MLC provisions published by the OECD By Tanja Velling For the second year running, the OECD provided an update on the two-pillared international tax reform project just days before Christmas....