12/23/2021 10:25:43 AM The “Danish cases” controversy: the Spanish Tax Authority makes its move By Miguel Cremades Schulz Following the path of tax audits stemming from the ECJ’s rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax...
7/20/2021 7:58:53 AM German Federal Ministry issued long-awaited decrees on cum/cum-transactions and securities lending By Sebastian Adam As an aftermath to recent fiscal court decisions on cum/cum transactions, the German Federal Ministry of Finance ("BMF") has reconsidered...
6/29/2021 2:56:32 PM Spanish National Court follows CJEU in placing burden of proving abuse on Spanish tax authorities By Guillermo Canalejo David López In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish...
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...
1/21/2021 10:47:18 AM Legal reform of German withholding tax regime to come By Sebastian Adam The German Government officially introduced a governmental draft for a reform of the German withholding tax (WHT) regime on 20 January...
1/5/2021 9:20:47 AM Foreign investment funds are exempt from withholding tax on Italian source dividends and capital gains on equities By Michele Dimonte Andrea Manzitti Starting on 1 January 2021, dividends and capital gains earned by qualifying EU/EEA based investment funds (EU/EEA Funds) are exempt from...
11/19/2020 2:39:39 PM Foreign investment funds may be eligible for Dutch dividend withholding tax refunds By Ingrid Mensing The Dutch Supreme Court decided in the Köln Aktienfonds Deka (KA DEKA) case that foreign investment funds are eligible for a refund of...