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European Union International Tax Issues

The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of... more +
The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -
Mayer Brown

Europe Daily News, 19 March 2024

Mayer Brown on

COMPETITION - Non-opposition to a notified concentration (Case M.11409 - Elia / Glentra / Energyre / Energyre Giga Projects USA) - Non-opposition to a notified concentration (Case M.11475 - Mitsui / Osaka Gas / RWE KK /...more

Conyers

Guiding Captives Through Global Developments

Conyers on

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

Conyers

British Virgin Islands Removed from EU Tax Blacklist

Conyers on

Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

BCLP

What You Need to Know About the Amendments to VAT in Para-Hotel Business

BCLP on

The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

Holland & Knight LLP on

More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Morgan Lewis

Draft Minimum Tax Directive Implementation Act: Minimum Taxation and Other Relevant Measures Legal Insights Germany

Morgan Lewis on

On August 16, 2023, the German federal cabinet approved the government draft bill to implement Council Directive (EU) 2022/2523 to ensure global minimum taxation and further accompanying measures (Minimum Tax Directive...more

Walkers

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on

This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

Ius Laboris

Telework from abroad: tax consequences for employers?

Ius Laboris on

As employers face growing calls to allow employees to ‘work from anywhere’, they should also consider the possible tax consequences of inadvertently creating a permanent establishment in another country. But what counts as...more

Hogan Lovells

New tax obligations for platform operators as Spain transposes DAC7

Hogan Lovells on

Pursuant to the transposition in Spain of the Council Directive (EU) 2021/514 of 22 March 2021 (so-called “DAC7”) and the implementation of the Model Rules for Reporting by Platform Operators developed by the OECD/G20 BEPS...more

Hogan Lovells

Doing business in Italy 2023

Hogan Lovells on

This booklet has been written specifically for business individuals and whilst it may be of interest to their local advisers, such as lawyers or accountants, the information is intended for a wider audience. We cover topics...more

Cadwalader, Wickersham & Taft LLP

EU List of Non-Cooperative Jurisdictions Expanded

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

Wilson Sonsini Goodrich & Rosati

European Court Expands Legal Professional Privilege in the EU

In a recent judgment, the European Court of Justice (ECJ) expanded the scope of Legal Professional Privilege (LPP) in the EU, recognizing that it is not limited to advice given for the purpose of defense but covers all...more

Cadwalader, Wickersham & Taft LLP

UK VAT Treatment of Fund Management Review Announced

As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Court of Justice Faults European Commission for Expansive Interpretation of State Aid in Tax Rulings

On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more

Cadwalader, Wickersham & Taft LLP

Getting the Fiats Straight: CJEU Annulled State Aid Decision against Fiat

On 8 November 2022, the Court of Justice of the European Union (the “CJEU”) set aside the EU General Court’s judgment of 2019 and annulled the European Commission’s State aid decision of 2015, which held that Luxembourg...more

Cadwalader, Wickersham & Taft LLP

Sub-Participations Are VAT Exempt Under EU Law

The Court of Justice of the European Union (the “CJEU”) held on 6 October 2022 in O. Fundusz lnwestycyjny zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”) that the supply of services provided by a...more

Hogan Lovells

ATAD 3 or the importance of adequate substance

Hogan Lovells on

At its dawn, the ATAD 3 Proposal and its adverse tax consequences were considered by some as the demise of international investment and holding structures. Others pointed out the uncertainties surrounding key terms related to...more

Goodwin

A New Direction for ATAD III Proposal?

Goodwin on

​​​​​​​Further to the request of the European Parliament for concerted EU action, the European Commission issued on 22 December 2021 a proposal for a Council Directive laying down rules to prevent the misuse of shell entities...more

Cadwalader, Wickersham & Taft LLP

EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit

In O. Fundusz lnwestycyjny Zamknięty reprezentowany przez O S.A. (Case C-250/21) (the “O Fundusz case”), Advocate-General Medina (the “AG”) of the Court of Justice of the European Union (“CJEU“) opined that the supply of...more

Cadwalader, Wickersham & Taft LLP

European Commission Consultation on EU-wide Withholding Tax System

The European Commission has launched a public consultation on its proposal to introduce a new common EU-wide system for withholding tax on dividend or interest payments. The consultation period will end on 26 June 2022....more

Proskauer Rose LLP

UK Tax Round Up - May 2022

Proskauer Rose LLP on

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Proskauer - Tax Talks

EU Commission publishes draft directive to remove tax driven debt-equity bias

Proskauer - Tax Talks on

Summary and Background - On 11 May 2022, the European Commission (the “Commission”) published its draft proposal for a debt-equity bias reduction allowance (“DEBRA” or, the “Directive”), which forms part of the...more

Orrick, Herrington & Sutcliffe LLP

Russian Exposure: Guidance for Tech Companies

This guidance does not constitute legal advice. To the extent that you have any questions arising out of the guidance, please speak to a member of the Orrick team who will be happy to assist. The invasion of Ukraine by...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Orrick, Herrington & Sutcliffe LLP

Fari accesi sulle società di comodo nella UE

In data 22 dicembre 2021, la Commissione Europea ha adottato una Proposta di Direttiva finalizzata a contrastare l’uso improprio ai fini fiscali delle società di comodo residenti nei paesi dell’Unione (“Proposal for a Council...more

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JD Supra Privacy Policy

Updated: Dec 28, 2021:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

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Collection of Information

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How We Protect Your Information

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Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
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You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

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How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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There are different types of cookies and other technologies used our Website, notably:

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JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

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Controlling and Deleting Cookies

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Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

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