5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
Le Conseil d’État juge que les quotes-parts de bénéfices perçues par une société dans des sociétés civiles doivent être traitées comme des produits financiers non soumis à la TVA, remettant en cause l’exonération de taxe sur...more
On 21 May 2025, the Danish Tax Agency published new guidelines introducing revised administrative practice on the procedure for obtaining VAT refunds in cases involving incorrectly invoiced output VAT. Previously, a refund...more
The French tax authorities have issued new guidelines on the VAT treatment of company cars provided to employees. When a vehicle is provided for a defined consideration, it is considered a taxable service. This includes...more
Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more
Le Tribunal administratif de Lille retient qu’un boni de fusion doit être pris en compte dans le chiffre d’affaires pour la détermination du rapport d’assujettissement à la taxe sur les salaires d’une société holding (TA de...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER TURKISH LAW - 1. Agreement Types - Pursuant to Turkish laws, a real estate sale and purchase agreement shall be in an official form and the transfer of ownership of real...more
Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more
Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more
On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...more
The new VAT law introduces several key changes including the scope of taxable transactions, clarification of "deemed sales", non-taxable items, tax rates and more....more
The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more
The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more
Company belonging to Euro 750 Mio Group, will pay DST regardless of their digital service turnover in Italy. ...more
Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more
1 January 2025 marked the entry into force of the obligation for Romanian established taxpayers that carry out taxable operations in Romania to report in the Romanian invoicing System the invoices issued in B2C transactions....more
Sonder Europe Limited (Sonder) leased self-contained apartments from landlords for 2 to 10 years, furnishing and decorating them if needed (without altering the fabric or structure of the apartment), and then sub-let them to...more
In general, foreign funds are not freely movable into China. There is a long history of exercising comprehensive control over foreign investment since China opened its door in the early 1980s. As the economy continues to...more
Types of business entities - The most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”), the corporation (“Sociedad Anónima” or “SA”)...more
Private Wealth Services attorneys Patrick Duffey and Brent Berselli discuss the future of tax policy with Tax attorney Joshua Odintz ahead of the 2024 election. The attorneys provide an overview of the 2017 Tax Cuts and Jobs...more
Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more
The German legislator is currently introducing a large number of tax law changes in various draft bills. This article provides an overview of the most important planned changes. The draft Annual Tax Act 2024 (JStG 2024)...more
Welcome to the September 2024 edition of our UK Tax Round Up. This month has seen decisions on UK tax residence, VAT group eligibility and the Supreme Court’s ruling in the long running case involving the employment status of...more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
The characterisation of fixed and floating charges remains a complex area, not least with respect to new intangible asset types. The key distinction between a fixed and a floating charge is well established as a matter of...more