Navigating Russia Sanctions
Private Equity and Delaware Law – Part One
On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more
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
HMRC has recently updated its guidance on the UK’s new qualifying asset holding company (QAHC) tax regime, which was introduced from 1 April 2022, to include examples of the application of the QAHC regime “activity condition”...more
HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate...more
The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
The new Spanish Controlled Foreign Company rules might have a major impact on non-resident holding companies, and particularly those resident in a country outside the EU and the EEA due to the controversial (and, in our view,...more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
• Switzerland’s privileged taxation of companies is no longer in line with international standards. • In 2017, the first attempt to abolish the internationally criticized regime was clearly rejected by Swiss voters. • On 28...more
VAT treatment of supplies of non-employed temps clarified - A recent Court of Appeal case – Adecco v HMRC – clarifies a longstanding question over seemingly contradictory case law on the VAT treatment of employment agency...more