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Torys LLP | Canada | 8 Dec 2023

Section 1446(f): the surprising reach of a U.S. withholding tax

With increased secondary market dealmaking, buyers and sellers of private equity funds should watch out for a U.S. withholding tax that has…
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Khaitan Legal Associates | India | 7 Dec 2023

Invoking M.F.N. Clause Under Indian Tax Treaties Requires Notification

Foreign investment in Indian businesses increased significantly since the liberaliza- tion measures adopted by the Indian government in the early…
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Grant Thornton Netherlands | Netherlands | 30 Nov 2023

New rules for conditional withholding tax on dividends

Are you also liable to withholding tax on dividends as of January 1, 2024? Starting from that date, the Conditional Withholding Tax on Dividends Act…
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Grant Thornton Netherlands | Netherlands | 30 Nov 2023

Nieuwe regels voor conditionele bronbelasting op dividenden

Bent u vanaf 1 januari 2024 óók inhoudingsplichtig voor de conditionele bronbelasting op dividenden? Vanaf dan is de Wet invoering conditionele…
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RPC | United Kingdom | 28 Nov 2023

Supreme Court rules on admissibility: Dicey, Cum/Ex and SKAT

The Supreme Court ruled that one of the largest fraud cases currently in the Commercial Court can proceed to trial commencing next April after finding that the claim is admissible in the English courts. The defendants had succeeded in persuading the first instance judge that the claimant, the Danish tax authority, was seeking to indirectly enforce Danish revenue or public law through the......
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Walder Wyss Ltd | Switzerland | 14 Apr 2023

Structuring of private equity acquisitions in Switzerland

The acquisition and sale of a Swiss company by a private equity fund is associated with numerous tax challenges that should be considered when setting up a suitable acquisition structure. This article explores these challenges and their consequences for buyers.
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Pinsent Masons | United Kingdom | 17 Mar 2023

UK holding companies – key tax considerations

After a protracted exit from the European Union, the United Kingdom continues to be one of the most attractive locations for holding companies. The (current, at least) UK government appears committed to ensuring it remains this way. This article considers the characteristics of the UK tax system and examines the key tax considerations for corporates looking to establish a holding company and......
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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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