In a recent ruling (No. 132 of 3 March 2021) the Revenue Agency has confirmed that SPVs used to secure proceeds from the direct ownership...
Starting on 1 January 2021, dividends and capital gains earned by qualifying EU/EEA based investment funds (EU/EEA Funds) are exempt from...
During OECD Tax Talks #17, Pascal Saint-Amans presented the Pillar One and Two Blueprints as a glass half-empty because no consensus has...
Amount A under Pillar One of the OECD’s two-pillared proposal for international tax reform would constitute a new taxing right for market...
Indemnity payments under a share purchase agreement are taxable in the hands of the purchaser, irrespective of their accounting...
In the tug of war between the Italian Parliament and Supreme Court in respect of the indirect tax treatment of indirect business...
A UK trust is a “person” for the purposes of the Italy-UK double tax treaty - that is the good news coming out of a recent Italian...
As countries ramp up social distancing measures to combat COVID-19, the economic costs of the virus spiral and the G7 leaders have called...
In the 2020 Finance Bill, the Italian Government announced its intention to combat tax evasion, thought to cost more than 100 billion...
«There is no liberty if the judiciary power be not separated from the legislative and executive» (C.L. de Montesquieu, The Spirit of...
Today is the first OECD Tax Certainty Day. We have asked some of our authors for their thoughts on the topic. One of my fellow panellists...
In her recent post, Tanja Velling highlights some of the uncertainties in the UK around the tax residence of a company. This is not just...
Italy is facing a dramatic outflow of “human capital”. According to Eurostat, only Romania and Poland pips Italy to the post in terms of...
BEPS legacies and ECJ recent decisions on the abuse of EU tax directives have increased the complexities around repatriating profits from...