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In this issue:

Focus Feature

Staying ahead of exponential change

Legal Developments


  • Interest-free loan was an indirect transfer of profits
  • Tax treaties: tax residence and the fact of being subject to taxes
  • Mergers Directive: is French implementation contrary to European Law?


  • Federal Fiscal Court challenges constitutionality of German interest barrier rule and refers it to the Federal Constitutional Court for decision

The Netherlands

  • Dutch fiscal unity possibilities expanded to non-European Economic Area structures


  • Qualification under the Spanish participation exemption regime on reimbursements received by Spanish companies derived from their stake in Maltese entities

United Kingdom

  • UK royalty tax changes set to impact IP holding structures
  • Tax in the Real World
  • Real estate: tax changes spell the end of offshore PropCos
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