Ishtar Sancho

Ishtar Sancho

A&O Shearman

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What Does 2025 Hold for the Global Minimum Tax (Pillar Two)?

Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more

1/17/2025  /  Corporate Taxes , EU , International Tax Issues , OECD , Pillar 2 , Poland , Spain , Tax Credits , Tax Reform

Revolutionising cross-border dividend taxation: implications of the CJEU's decision in Credit Suisse Securities (Europe) Ltd

The recent decision of the Court of Justice of the European Union (CJEU) in C-601/23 Credit Suisse Securities (Europe) Ltd v. Diputación Foral de Bizkaia represents a transformative development in CJEU Case Law, one that...more

12/26/2024  /  Court of Justice of the European Union (CJEU) , Cross-Border , EU , Regulatory Agenda , Tax Authority , Tax Treaty , Taxation

Will Unshell be washed away? An uncertain future for ATAD 3 - the EU’s tax proposal on shell entities

The European Commission put forward a proposal in 2021 to tackle shell entities (known as ATAD 3). Despite widespread support for the concept, reaching agreement on the technical details of the Unshell Directive has proved...more

7/14/2023  /  Anti Tax Avoidance Directive (ATAD) , EU , European Commission , International Tax Issues , Shell Corporations , Tax Avoidance
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