European Tax

On 26 June, Australia's Full Federal Court decided in favour of Pepsi on appeal, flipping the initial decision which had been in favour...

HMRC v Burlington Loan Management DAC is an important decision for the smooth running of secondary debt markets. It is also a helpful...

In Hargreaves Property Holdings Limited v HMRC, the Court of Appeal dismissed the taxpayer’s appeal against the Upper Tribunal’s decision...

The Upper Tribunal’s decision is a helpful ‘back-to-basics’ on the nature and purpose of the provisions on withholding tax on interest...

A recent Italian Supreme Court decision could have far-reaching consequences for Italian tax provisions on cross-border dividend...

Italian Supreme Court Decision No. 3380 of 3 February deals with the interpretation of the beneficial owner (BO) requirement under the...

The German legislature has enacted a large number of new and amending provisions with remarkable speed, just before the current...

As an aftermath to recent fiscal court decisions on cum/cum transactions, the German Federal Ministry of Finance ("BMF") has reconsidered...

On 24 February 2021, the Spanish Supreme Court handed down a significant ruling which prohibits differences in tax treatment between...

A 22 December 2020 ruling from the Spanish Supreme Court (the Ruling) has confirmed that taxing non-Spanish resident pension funds on...

The German Government officially introduced a governmental draft for a reform of the German withholding tax (WHT) regime on 20 January...

Although the UK left the EU at 11pm on 31 January 2020, most people would not have noticed any change because the effect of the...

Starting on 1 January 2021, dividends and capital gains earned by qualifying EU/EEA based investment funds (EU/EEA Funds) are exempt from...

The German Ministry of Finance (BMF) published the first guidance on one of the most hotly discussed German tax issues of the year on...

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

The European Securities and Markets Authority (ESMA) has recommended legislative change to enable National Competent Authorities (NCAs)...