8/11/2025 10:40:10 AM Italian tax on dividends contrary to Parent Subsidiary Directive: details and implications By Michele Dimonte Dividends received by Italian financial intermediaries (including banks) from their subsidiaries are subject to Italy’s regional tax on...
1/27/2025 12:59:21 PM Europe's Decision on Bizkaia's Withholding Tax: Key Implications for International Investments By Iratxe Celaya Cristina Puerta On 19 December 2024, the Court of Justice of the European Union (CJEU) delivered a significant decision in the case of Credit Suisse...
10/29/2024 1:37:43 PM Ireland introduces a participation exemption for foreign distributions By Fintan Clancy Orlaith Kane Ailish Finnerty David Kilty +1 more... Show less The long-awaited legislation for the introduction of a participation exemption for non-Irish dividends and distributions was included in...
10/7/2022 8:37:02 AM Italian Supreme Court sets aside discriminatory tax framework for non-EU pension funds based on free movement of capital By Giampaolo Genta Simone S. Schiavini A recent Italian Supreme Court decision could have far-reaching consequences for Italian tax provisions on cross-border dividend...
9/22/2021 3:50:25 PM German tax laws pushed through before end of current parliamentary term By Verena Klosterkemper The German legislature has enacted a large number of new and amending provisions with remarkable speed, just before the current...
5/4/2021 1:58:57 PM The cautionary tale of Mr Bostan Khan By Mike Lane On 30 April 2021 the Court of Appeal handed down its unanimous judgment in Bostan Khan v HMRC. As tax cases go, it is neither the biggest...
2/2/2021 12:00:00 AM Non-Spanish resident pension funds are entitled to the refund of withholding tax on dividends paid by Spanish resident companies By Guillermo Canalejo Blanca García A 22 December 2020 ruling from the Spanish Supreme Court (the Ruling) has confirmed that taxing non-Spanish resident pension funds on...
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...
11/12/2020 6:45:55 PM Main highlights of 2021 Spanish tax reforms By Javier Arregui Alex Pié Shortly after the approval of the new Financial Transaction Tax and Digital Services Tax, the Spanish Government has submitted to...
11/11/2020 11:34:58 AM Spanish scrip dividends: Let the shareholder decide! By Miloslava Ilcheva In the last years, scrip dividends had become a very popular equity remuneration scheme for Spanish listed companies, as it helped them...
9/25/2020 12:00:00 AM Cum/ex schemes: ESMA recommendations By Tanja Velling The European Securities and Markets Authority (ESMA) has recommended legislative change to enable National Competent Authorities (NCAs)...
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...
9/17/2020 12:00:00 AM Spanish courts adhere to Danish conduit cases By Ángel Viñas When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court...
9/10/2020 12:08:57 PM New Dutch position on Brazilian interest on net equity is contestable By Yolande Wu Maarten van der Weijden On 28 August 2020, the Dutch State Secretary of Finance issued a policy decision (the "Decision") on the treatment of the juros sobre o...
8/7/2020 9:40:45 AM First criminal judgement on cum/ex transactions published in Germany By Sebastian Adam The 12th Criminal Division of the Regional Court of Bonn gave its judgement in the first criminal trial on cum/ex transactions in Germany...
7/29/2020 2:52:04 PM Dutch courts embrace Danish conduit cases By Maarten van der Weijden Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to...