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Repatriation of Italian dividends made simple. Or not? BEPS legacies and ECJ recent decisions on the abuse of EU tax directives have increased the complexities around repatriating profits from Italy by way of dividend. Some recent Italian Supreme Court’s decisions have added unnecessary confusion to this...
FinTech Alliance - Proof the UK is no longer a challenger On Tuesday the chancellor, Philip Hammond, announced the launch of the fintech Alliance, an initiative to bring together various elements of the disparate UK fintech environment to cement its position as a "powerhouse". As one would expect, the...
French Digital Services Tax: is this interim measure compliant with higher legal standards? Introduced as a temporary measure designed to deal promptly with one of the main challenges faced by international tax law - coping with an ever changing modern economy - the French Digital Services Tax (the “French DST”) was recently adopted by the...
Does your office plant really improve your work? Until relatively recently,  very little thought was given to where and how we work.  The psychological impacts of architecture and design, while they have been studied for decades, seem to have attracted very little media attention.  Despite staff costs...
Read your tax rulings carefully..... A recent UK tax tribunal decision, relating to the UK corporation tax treatment of a “tower” structure, serves as a useful reminder of the limitation of tax rulings. In 2013, Oxford Instruments needed to refinance its US sub-group. With its tax advisors,...
Are regulators ready for blockchain? Your weekly grocery shopping, high street fashion, designer goods, and bottles of whisky. These are just some of the many products and markets that have employed blockchain technology to manage supply chains, track goods, prevent counterfeiting, increase...
Member of management board can constitute a German taxable presence of a foreign company In a decision dated 23 October 2018 (I R 54/16), but only published on 17 April 2019 the German Federal Fiscal Court (Bundesfinanzhof – “BFH”) held that the managing director of a foreign company can qualify as a German permanent representative within the...
Collaborate: introducing our first cohort We are delighted to announce the first cohort of legal tech developers for Slaughter and May Collaborate, our new legal tech programme. The six businesses, selected by the Collaborate team alongside the programme’s client and expert panels, were chosen...
Repatriation of German-source profits reloaded? Pretty much any German inbound-investment has to consider how profits can be extracted in the most tax-efficient manner. In principle, dividend distributions carry a 25% German withholding tax (plus the solidarity surcharge of 5.5% thereon). German...
ECJ beneficial ownership cases: the end of the Dutch safe harbor rules in sight? Two ECJ rulings of 26 February 2019 cast doubt on whether safe harbour rules applied by the Netherlands are compliant with EU law.  Under these safe harbour rules, an abuse of EU law is deemed not to exist, and consequently benefits under the Interest and...