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...
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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...
Parent-subsidiary exemption: Spanish court recognises its application to a Luxembourg holding company
The Spanish National High Court (‘the High Court’) has issued a judgment (‘the judgment’) on the entitlement of a non-resident taxpayer...
Reported to the Italian tax authorities under DAC6? Here's what happens next
With the first DAC6 reporting deadline approaching, it may be that certain arrangements need to be reported to the Italian tax...
Leveraged cash-outs: is the tax saving legitimate?
A leverage cash-out is a transaction whereby:
- the original shareholder steps up the tax base in the participation of the target company by...
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