5/2/2025 2:19:03 PM Transfer pricing, permanent establishment and diverted profits tax reform – draft legislation By Alex Sim Gianni Prenol As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft...
4/28/2025 3:58:18 PM UK tax changes on the horizon By Tanja Velling How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax...
3/20/2024 1:42:23 PM Recent developments in respect of the Italian investment management exemption regime By Francesco Saverio Scandone Bernardo Leoni Does an Italian investment manager create a permanent establishment for a foreign investment vehicle? Not necessarily – especially now...
2/21/2024 5:14:20 PM Fine-tuning in international tax planning – the art of allocating head office’s management expenses to its foreign permanent establishments By Daniel Alió Euvrard The Spanish Supreme Court recently ruled on the criteria to be used to allocate (part of) the general management and administrative...
1/17/2024 5:10:35 PM The DPT is dead; long live the DPT! By Slaughter and May Having introduced more than twenty brand-new taxes since the turn of the millennium — at a rate of roughly one new tax per year — did the...
6/23/2023 9:31:48 AM Transfer pricing, permanent establishment and diverted profits tax reform By Tanja Velling The changes proposed by the UK government in its consultation on the reform of the transfer pricing, permanent establishment and diverted...
5/20/2022 12:26:27 PM Permanent establishment risk for virtual asset service and e-wallet providers in Italy By Michele Dimonte One of the consequences of the entry-into-force of the Italian requirement for virtual asset service providers (VASPs) and e-wallet...
3/25/2022 11:49:59 AM The potential Spanish permanent establishment of remote workers during and after COVID-19 By Eduardo González Ángel Viñas The Spanish tax authorities have recently published a binding tax ruling (V0066-22 dated 18 January 2022) which concluded that, in...
12/14/2021 2:24:23 PM Valueclick case: Paris Administrative Court of Appeal finds French permanent establishment By Yves Rutschmann Victor Camatta In a decision dated 11 December 2020 (Valueclick case), previously covered in this blog, the French Administrative Supreme Court (Conseil...
1/29/2021 5:12:45 PM Revised OECD tax treaty guidance as “temporary” COVID-19 travel restrictions continue to impact business operations By Kasim Mehmood The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on...
12/14/2020 12:00:00 AM Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent” By Victor Camatta Pierre-Marie Roch In a decision dated 11 December 2020 (no 420174), the French Administrative Supreme Court (Conseil d’Etat) overturned the decision of the...
10/19/2020 9:17:53 AM Voluntary disclosure of “hidden” PE in Italy: it’s time for rejuvenation By Michele Dimonte Three years after entering into force, the time has come to assess the effectiveness of the voluntary disclosure procedure for hidden...
4/22/2020 12:33:48 PM Egyptian branch remittance tax: potential increase and compatibility with double tax treaties By Mostafa Elfar The Egyptian Government recently announced plans to limit the application of a reduced rate of dividend withholding tax under the...
4/8/2020 3:02:49 PM COVID-19 impact on PEs and residence: HMRC and OECD guidance By Stephanie Mullins HMRC has issued guidance providing some comfort in respect of the question whether employees who do not normally work in the UK, but are...
10/11/2019 3:57:19 PM Dutch 2020 Budget: the end of an era By Maarten van der Weijden The Dutch government has released its budget plans for 2020, as well as certain tax proposals. The introduction of a withholding tax on...