Expert Analysis

Irish section 110 finance companies now commonly feature in international finance structures. Over the years their use has expanded from being the issuing vehicle in more traditional securitisation and repackaging type transactions, to a broader range of applications, such as being the issuers of Islamic finance instruments, distressed debt acquiring companies, the underlying vehicle for US life settlement funds, and, more recently as aircraft leasing companies. James Somerville of A&L Goodbody explores this trend in light of recent guidance.

Stephan Eilers and Alexander Schwahn of Freshfields Bruckhaus Deringer provide a brief overview of a classic structure for a private equity investment in Germany, and they critically analyse the efforts of both the tax authorities and the legislature to place restrictions on debt push-down structures.

With the UK facing constraints in attracting capital for infrastructure projects, Margaret Stephens and Mikko Saressalo of KPMG explain why the government is turning to tax to encourage more investment in this sector.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Mithilesh Reddy of Steadfast Business Consulting outlines how the qualified domestic minimum top-up tax is reshaping multinational tax planning, compliance, and strategic operational structures in the UAE

Maria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied