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...
5/19/2021 10:26:18 AM From CCCTB to BEFIT: the European Commission's plan to future-proof taxation By Tanja Velling The Commission's Communication on Business Taxation for the 21st century sets out reams of important tax policy announcements, whilst...
3/4/2021 12:00:00 AM The corporation tax rise in pictures... By Mike Lane For those who prefer to think in pictures, this chart from the OBR's 2018 report "Why have onshore CT receipts performed so well since...
12/17/2020 12:00:00 AM Dutch Supreme Court rules on applicability of participation exemption in the context of uncovered call options and benefits from German cum/ex trades By Ingrid Mensing Recently, the highest court in the Netherlands ruled that (a) uncovered call options cannot be regarded as a participation, and (b)...
9/18/2020 12:00:00 AM Highlights from the 2021 Dutch Budget By Maarten van der Weijden The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate...
8/15/2019 12:00:00 AM Proposed ATAD 2 hybrid rules in the Netherlands will have a far-reaching impact By Wiebe Dijkstra On 2 July 2019, the Dutch government published a bill implementing the second EU anti-tax avoidance directive (ATAD 2). Once enacted, the...
8/5/2019 10:20:01 AM What are your losses worth? By Tanja Velling Subject to a £5m deduction allowance, UK corporation tax payers may use carried-forward income losses against up to only 50% of their...