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In this issue:

FOCUS FEATURE

European crackdown on tax avoidance: what will it mean in practice?

  • Implications of the ATAD for Belgium
  • What are the effects of the ATAD in France?
  • Expected impact in the Netherlands
  • How will the Brexit vote affect the UK adoption of ATAD?

LEGAL DEVELOPMENTS

Azerbaijan

  • Azerbaijan reforms bring its tax system into line with international tax practices

France

  • The 3 percent tax on dividend distributions is seriously put to the test by a superior rule of law

Germany

  • Relevance of a right to name the acquiring entity in M&A transactions for German real estate transfer tax purposes
  • New proposal for additional relief from loss cancellation rules on a change of ownership

Spain

  • Tax treatment of dividend payments in double holding structures where ultimate shareholder is non-EU resident
  • Transfer Pricing analysis of professional services provided by related-party individuals and corporations
  • Difference in tax treatment of Brazilian Juros for tax treaty and domestic law purposes

United Kingdom

  • Losing control - restrictions on the availability of group relief
  • Tax refund claims on interest and royalty payments: a UK perspective on Brisal
  • New UK royalty withholding tax and hybrid rules: how much change is needed?
  • Real estate: tax changes come into force
  • Terminal complexity: proposed changes to UK rules on employee termination payments
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