Ogier | British Virgin Islands | 16 Sep 2021
The Economic Substance (Companies and Limited Partnerships) (Amendment) Act 2021 extends the economic substance regime under the Economic Substance (Companies and Limited Partnerships) Act 2018 to limited partnerships without a legal personality. Following its enactment, there will be a six-month transitional period for existing partnerships without a legal personality that were formed before......
PHH Rechtsanwälte | Austria | 14 Sep 2021
While it has its origins in the Habsburg monarchy, the Stamp Duty Act (SDA) is still in force as of today, despite banks' repeated calls for its abolishment. The SDA contains an exhaustive list of legal transactions that are subject to stamp duty in Austria if certain legal prerequisites are met. This article answers FAQs about stamp duty requirements in Austria.
Gorodissky & Partners | Russia | 30 Jul 2021
Russia has denounced its agreement with the Netherlands on double taxation avoidance and tax evasion provisions relating to income and property tax. The termination of the agreement is set for 1 January 2022. It is the first denouncement of a tax agreement in Russian history.
Fischer (FBC & Co) | Israel | 11 Jun 2021
While traditional initial public offerings (IPOs) have become risky, difficult and vulnerable to conflict as to the issuer's valuation, a merger or combination with an IPO-funded special purpose acquisition company (SPAC) offers an alternative. The recent popularity of SPACs can be linked to, among other things, their structure, which provides advantages and benefits for investors, sponsors......
Walder Wyss Ltd | Switzerland | 11 Jun 2021
In Switzerland, 1% issuance stamp duty is levied on capital contributions from shareholders to Swiss companies. This stamp duty is curbing capital injections as these costs induce shareholders to finance Swiss companies through shareholder loans. Such a financing strategy turns out to be especially harmful in an economic crisis. Against this backdrop, the Council of States of Parliament......
William KW Leung & Co | Hong Kong | 10 Jun 2021
It is trite law that the Hong Kong courts will not enforce a foreign arbitral award if it amounts to indirect enforcement of foreign laws. In the context of tax law, a defence known as the 'tax gathering' defence exists, under which a foreign award will not be enforced if it would, in effect, help foreign states to collect taxes. However, the requirements of this defence have been unclear....
Lewis Silkin | United Kingdom | 9 Jun 2021
The increase in homeworking due to the COVID-19 pandemic is causing many employees to ask whether they can work from 'home' from an overseas country – be that on a temporary basis or indefinitely. Employers should consider a variety of issues before agreeing to an employee's request to work from home when 'home' is not in the United Kingdom. This article discusses the issues and sets out......
Gorodissky & Partners | Russia | 4 Jun 2021
Numerous amendments to Federal Law 290-FZ on International Companies and International Funds recently entered into force, expanding the opportunities for international companies to redomicile to Russia and for international holding companies to enjoy tax benefits. This article examines the requirements around redomiciliation and the main amendments to the law.
Studio Legale e Tributario Biscozzi Nobili Piazza | Italy | 21 May 2021
Budget Law 2020 (amending Law 145/2018) provided for the entry into force – as of 1 January 2020 – of a digital services tax (DST). With Circular 3/E of 23 March 2021, the Italian Revenue Agency provided clarifications regarding DST, taking into account the implementation rules as set out in the provision of 15 January 2021.
Pinsent Masons | United Kingdom | 19 May 2021
The chancellor of the exchequer recently announced an extensive review of the research and development tax relief system to ensure that "the UK remains a competitive location for cutting edge research, that the reliefs continue to be fit for purpose and that taxpayer money is effectively targeted". The life sciences sector is strongly encouraged to respond to the consultation to ensure that......