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Walder Wyss Ltd | Switzerland | 7 Oct 2022

Swiss reject tax reform aiming at strengthening domestic debt capital markets

🕑 3 minutes The people of Switzerland recently rejected the changes to the national withholding tax and stamp duty regime that would have led to an abolition of withholding tax on bond yields and interest income of Swiss funds, despite backing from the Swiss government and Parliament. The reform proposed by the Federal Council was primarily aimed at facilitating the withholding tax-free......
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Bowditch & Dewey LLP | USA | 8 Sep 2022

Update Your Tax Withholdings to Avoid Year-End Surprises

During the 2022 tax filing season, many taxpayers had an unpleasant surprise when they filed their tax return and found out they were getting a much…
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Loyens & Loeff | Luxembourg, United Kingdom | 9 Jun 2022

Luxembourg signs new tax treaty with the United Kingdom

As per the protocol to the Treaty, a Luxembourg collective investment vehicle (CIV) set up in the form of a body corporate for tax purposes (e.g., a…
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Loyens & Loeff | Switzerland | 11 May 2022

Amendments to exemption at source for Swiss withholding tax as of January 1st, 2023

The requirements for the exemption at source from Swiss dividend withholding tax will be improved as of January 1st, 2023. The exemption will apply…
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Skadden Arps Slate Meagher & Flom LLP | Germany | 29 Apr 2022

Navigating the Once-Obscure German Nonresident Withholding Tax

In this episode of Skadden’s “GILTI Conscience” podcast, partners Nate Carden and David Farhat discuss the German nonresident withholding tax with…
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VdA | Portugal | 22 Apr 2022

WHT on dividends obtained by non-resident collective investment undertakings is not applicable in Portugal

The European Court of Justice has confirmed in Allianzgi-Fonds Aevn that the withholding tax (WHT) that is applicable on dividends paid to non-resident collective investment undertakings in Portugal is incompatible with EU law. It is now up to the Portuguese legislature to amend domestic rules to align the WHT regime that is applicable on dividends obtained by investment funds, eventually......
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SyCip Salazar Hernandez & Gatmaitan | Philippines | 25 Mar 2022

BIR updates its procedures for claiming tax treaty benefits

In the Philippines, the requirement period for tax treaty benefit entitlement has been an issue between different government agencies. The Philippine Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Order No. 014-21, which streamlines the procedures for non-resident corporations and other juridical entities to access Philippine tax treaty benefits.
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Walder Wyss Ltd | Switzerland | 25 Mar 2022

Withholding tax and securities transfer tax reform aims to strengthen debt capital market

The recent abolition of the withholding tax on bonds and the remaining proposed changes to the withholding tax and securities transfer stamp tax regime are expected to boost Switzerland's position as an international finance and treasury centre. All types of financing and refinancing activities in Switzerland will be facilitated as adverse withholding tax consequences can be fended off.
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Loyens & Loeff | Belgium, Hong Kong, Ireland, etc. | 25 Mar 2022

Holding Regimes in a New Era - 2022 edition

This publication provides a practical tool to compare key features of the covered jurisdictions. Initially developed as an internal tool for our tax…
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RPC | United Kingdom | 15 Mar 2022

Court of Appeal draws distinction between claims for recovery of tax and restitution for tax paid out fraudulently

The Court of Appeal recently investigated in detail the operation of rule 3(1) of Dicey, Morris & Collins on the Conflict of Laws (edition 15) (Dicey rule 3), which provides that English courts do not have jurisdiction over actions for "the enforcement, either directly or indirectly, of a penal, revenue, or other public law of a foreign State". This case was an appeal by the Danish tax......
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