European Tax

Under the current legislation, Italy taxes non-resident entities only on capital gains derived from a direct sale of Italian immovable...

With Article 7 of the OECD's Multilateral Instrument containing a Principal Purpose Test (or PPT) tax authorities, taxpayers and tax...

Multinational companies increasingly face situations where two or more countries seek to tax the same profits. Recently enacted and...

Nowadays, due to factors such as the greater mobility of people and capital, inheritances and gifts with an international component have...

The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on...

With effect from the end of the Brexit transition period, the UK will revoke the Double Taxation Dispute Resolution (EU) Regulations 2020...

The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the...

Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD)...

The ‘cum-ex scandal’ being the nut in question here. After a consortium of journalists uncovered schemes generating multiple refunds of...

Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC....

It sounds like a bad joke, befitting of a tax lawyer in lockdown, but is really just a reminder to check the small print in double tax...

A UK trust is a “person” for the purposes of the Italy-UK double tax treaty - that is the good news coming out of a recent Italian...

The OECD Secretariat proposal for a unified approach published today for consultation until 12 November focuses on Pillar One (nexus and...

In a recent decision, concerning claims for group loss relief by Irish subsidiary companies of a Delaware LLC, the Irish Tax Appeals...