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Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Marco 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
Stephanie Eichenberger and Thomas Zellweger of Tax Partner explain how the choice of investment vehicle impacts the eligibility of non-Swiss investors for Swiss withholding tax refunds and, ultimately, investment performance
Francesco Di Bari of Alma LED explains how an Italian Supreme Court ruling marks a pivotal shift in the tax treatment of interest on indirect lending, restoring key exemptions for qualified foreign institutional investors
