Europe
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation -
Sponsored by Garrigues SpainRafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty
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Sponsored by Alma LEDMarco Sandoli and Lorenzo Marantonio of Alma LED challenge the Revenue Agency’s ‘unsupportable’ interpretation on tax exemptions for business and shareholding transfers through trusts when taxation is applied at the time of asset segregation
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European Jurisdictions