News & Analysis as of August 31, 2025

Income Taxes

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The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -

La différence de traitement des quotes-parts de frais et charges selon la localisation des filiales conforme à la CEDH

Mayer Brown on 3/20/2025

La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on 5/31/2024

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on 10/20/2023

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

Draft Minimum Tax Directive Implementation Act: Minimum Taxation and Other Relevant Measures Legal Insights Germany

Morgan Lewis on 9/27/2023

On August 16, 2023, the German federal cabinet approved the government draft bill to implement Council Directive (EU) 2022/2523 to ensure global minimum taxation and further accompanying measures (Minimum Tax Directive...more

EU List of Non-Cooperative Jurisdictions Expanded

Cadwalader, Wickersham & Taft LLP on 2/28/2023

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit

Cadwalader, Wickersham & Taft LLP on 7/25/2022

In O. Fundusz lnwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”), Advocate-General Medina (the “AG”) of the Court of Justice of the European Union (“CJEU“) opined that the supply of...more

UK Tax Round Up - May 2022

Proskauer Rose LLP on 6/8/2022

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

EU Commission publishes draft directive to remove tax driven debt-equity bias

Proskauer - Tax Talks on 5/25/2022

Summary and Background - On 11 May 2022, the European Commission (the “Commission”) published its draft proposal for a debt-equity bias reduction allowance (“DEBRA” or, the “Directive”), which forms part of the...more

International News: Spotlight on Tax

McDermott Will & Schulte on 5/5/2022

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

UK Tax Round Up - January 2022

Proskauer Rose LLP on 2/10/2022

UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Partial Brexit? For income tax treaty purposes, US and UK competent authorities vote to remain

Eversheds Sutherland (US) LLP on 8/4/2021

While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the United Kingdom will remain in the EU for purposes of the US-UK Income Tax...more

UK Tax Round Up - February 2021

Proskauer Rose LLP on 3/10/2021

UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

UK Tax Round Up - November 2020

Proskauer Rose LLP on 12/3/2020

UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

UK Tax Round Up - May 2020

Proskauer Rose LLP on 6/3/2020

UK COVID-19 developments - Proposed deferral of DAC6 and DAC2 - The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more

UK Tax Round Up - April 2020

Proskauer Rose LLP on 5/12/2020

Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more

Appalti (E Non Solo…): Nuovi Oneri Per Il Committente

Orrick, Herrington & Sutcliffe LLP on 2/6/2020

Il Decreto Legge 26 ottobre 2019, n. 124 (cosiddetto «Decreto Fiscale») – convertito, con modificazioni, dalla legge 19 dicembre 2019, n. 157 – ha introdotto nuovi oneri a capo del committente che affidi a soggetti terzi il...more

UK Tax Round Up - January 2020

Proskauer Rose LLP on 1/31/2020

UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

UK Tax Round Up - October 2019

Proskauer Rose LLP on 10/31/2019

UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

UK Tax Round Up - September 2019

Proskauer Rose LLP on 10/7/2019

Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

[Event] 2019 Tax In The City®: Seattle - October 24th, Seattle, WA

McDermott Will & Schulte on 9/25/2019

We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more

UK Tax Round Up - December 2018

Proskauer Rose LLP on 12/31/2018

UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

UK Tax Round Up - September 2018

Proskauer Rose LLP on 10/8/2018

UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

UK Tax Round Up - April 2018

Proskauer Rose LLP on 5/1/2018

General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

UK Tax Round Up - February 2018

Proskauer Rose LLP on 2/23/2018

Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

UK Tax Round Up - January 2018

Proskauer Rose LLP on 1/29/2018

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

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