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Feature

  • IRS to obtain US bank information on Finnish residents with US bank accounts

Case Summaries

France

  • Management packages: criteria in tax matters keep being clarified
  • The bonus paid by a sport federation to a professional player provided by the club that employs him is a salary

Switzerland 

  • Baker McKenzie obtains a landmark judgment favouring lenders in relation to negative interest

United Kingdom

Legislative Developments

Argentina

  • Compliance with BEPS Action 5 commitments

Belgium

  • Belgium Cayman Tax: publication of an extended blacklist of entities established outside the EEA
  • Belgium introduces a withholding tax exemption for Belgian resident individuals receiving "dividends" in the context of a "spin-off"
  • Belgium introduces a withholding tax exemption for Belgian resident individuals receiving "dividends" in the context of a "spin-off"

France

  • Withholding of income tax: review of some practical issues

Italy 

  • Italian Italy broadens the scope of the special tax regime for new resident workers (70% to 90% exemption from income tax)

Malaysia

  • Malaysian Stamp Act: Changes to relief provisions, instruments that secure indebtedness and rates increase

The Netherlands

  • From 2020, Dutch businesses must register their beneficial owners 

Philippines

  • BIR issues revenue regulations for tax amnesty on delinquencies

South Africa

  • Tightening the noose on foreign trusts

Spain

  • European Commission requests that Spain eliminate discrimination against non-resident individuals' rental income 

United Kingdom

  • No more room to manoeuvre – UK capital gains tax extension for non-residents
  • Will an end to the "blame game" help the UK keep its title as "divorce capital of the world"?
  • National Crime Agency secures second set of Unexplained Wealth Orders 

United States

  • US Department of Justice issues update to its guidance on evaluating corporate compliance programs
  • The new 2019 QOZ-proposed regulations and their impact on the life cycle of a Qualified Opportunity Fund
  • Three new LB&I compliance campaigns for pass-through entities
  • California legislature proposes a state gift and estate tax beginning 2021
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