European Tax

Dividends received by Italian financial intermediaries (including banks) from their subsidiaries are subject to Italy’s regional tax on...

Following the path of tax audits stemming from the ECJ’s  rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax...

In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish...

When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court...

Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to...

For the first time, the Dutch Supreme Court has denied the benefit of the EU Parent-Subsidiary Directive based on the existence of a...

On 24 October, Advocate General (AG) Hogan opined that a company incorporated, and subject to corporation tax, in Gibraltar cannot avail...

BEPS legacies and ECJ recent decisions on the abuse of EU tax directives have increased the complexities around repatriating profits from...