What’s the impact of the proposed restrictions to the UK sovereign immunity tax exemption?
The UK government recently published an unexpected consultation setting out proposals to both legislate and reform the existing UK...
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Double tax treaties: the French supreme court rules that beneficial ownership can be used affirmatively by taxpayers and the French tax authorities
In this blog, we examine the recent, and helpful, Planet case (20 May 2022, #444451, Société Planet; concl. C. Guibé), in which the
Does the proposed UK corporate re-domiciliation regime measure up?
The UK government is planning to introduce a UK corporate re-domiciliation regime that would allow a non-UK incorporated company to...
Withholding tax issues on Facility Agreements: traps for the unwary
The basic position on withholding taxes in LMA facility agreements is often summarised by saying that the borrower only takes change of...
The Netherlands' 2022 tax plan
On 21 September 2021, the 2022 Netherlands tax plan ('the tax plan') was presented by the Minister of Finance to the lower house of the...
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