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Taxing the digitalized economy

The so called “new taxing right” would be an overlay to existing nexus and profit allocation rules.

Tax Blockers and US CLOS: Best Practice for Restructuring Distressed Assets

In line with prior downturns, over the last number of months we have seen a significant rise in the formation of 'tax blocker' subsidiaries for existing US CLO issuers with exposure to affected assets.

Cayman Islands: Updates regarding DITC portal and CRS and FATCA compliance

The update advises that the CRS reporting functionality in the DITC portal has been re-enabled

Users as digital assets: highlights from a tax perspective

Therefore, users are to be taken into account as important assets for enterprises, capable of driving and changing the taxation approach of various transactions.

Tax avoidance not a main purpose of transaction, says UK tribunal

It was originally envisaged that the consideration for the sale would be a mixture of cash and ordinary shares issued by the purchaser.

Swiss bank pays up to settle German tax evasion probe

A long-running dispute with Germany is fading now that both countries and others automatically exchange data about bank accounts.

UK Footballers and their agents face increased tax bills as HMRC clamp down on perceived tax loophole

The element of the payment which is made on behalf of the player will be treated as taxable income of the player as a ‘benefit in kind’.

No or only nominal tax jurisdictions carry out first annual information exchanges

The information to be exchanged relates to the identity, activities, and ownership chain of entities that are noncompliant with substance requirements or that engage in “high-risk” activities, such as activities relating to intellectual proper

Beware the offshore tax crackdown

The offshore financial interests of millions of Britons have been handed to HMRC since 2018

You heard NY finalized its budget: What does this mean for the art world?

While some may forecast a negative impact on the art market as collectors may have less cash in their pockets available for discretionary purchases (like art), we do not think this tax change spells all doom and gloom.

New carbon price makes energy efficiency in the German building sector even more important

It is expected that the costs incurred as a result will be passed on by the so-called distributors to their customers, and therefore to anyone who uses fossil fuels.

New US proposals for reforming the international tax system

The Organisation for Economic Cooperation and Development (OECD) has been working on proposals for addressing the tax challenges of the digitalisation of the economy for a number of years.

Luxembourg: Tax assessments: Pre-litigation and litigation procedures for corporate taxpayers

This article provides a brief overview of the key elements of the procedural framework for contesting decisions issued by the LTA, as applicable to corporate income tax, municipal business tax, and net wealth tax.

Dentons Canada is successful in a Tax Court decision involving section 160 of the Income Tax Act and the General Anti-Avoidance Rule

The negotiated price was higher than the amount of the proceeds that would have remained in the subsidiaries after paying taxes from the land sale.

Tax