Features

Italy’s Supreme Court has issued a controversial decision on the requirements necessary to benefit from withholding tax (WHT) exemptions on profits distributed to companies resident in other EU member states. Chiomenti’s Paolo Giacometti and Raul-Angelo Papotti discuss what this means for the Parent-Subsidiary Directive.

Taxing multinationals in the digital services sector has remained a complex international challenge for local governments limited in their jurisdictional capabilities. Tremonti’s Lorenzo Piccardi, Simone Zucchetti and Armando Tardini discuss how Italy is facing these challenges through regulatory developments surrounding permanent establishments and web taxes.

Italy has one of Europe’s most active leveraged buyout markets, and local regulators have been eager to ensure such activity is sufficiently taxed. LED Taxand’s Guido Arie Petraroli and Patrizio Braccioni explore recent legislative tax changes in Italy and Europe and how this will impact private equity activity.

Mexico’s economy has made notable gains in the past decade, bringing opportunities for financially healthy Mexican corporations to exploit leveraged recapitalisations. Galicia Abogados’ Federico Scheffler and Sebastián Ayza discuss the tax implications and impact for mergers and acquisitions (M&A).

China has implemented venture capital (VC) tax rules at the same time economic substance requirements for key offshore centres have been introduced. KPMG’s Michael Wong, Christopher Mak and Alan O’Connor highlight the key considerations for businesses.

Switzerland’s federal tax administration has published an update on its tax ruling practice for federal taxes, withholding taxes (WHT) and stamp duty as it nears a second referendum on corporate tax reform. burckhardt Switzerland’s Rolf Wuethrich explores how these may affect tax structuring and merger and acquisition (M&A) sentiment.