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1
Japan Legal Update Vol. 42 | November 2018
On October 22, 2018, the Agency for Natural Resources and Energy published an "Overview on Draft Ministerial Order on Partial Revision of Ordinance for Enforcement of Act on Special Measures ...
Japan
4 Dec 2018
2
First Conviction In The United States For FATCA Violations
The former head of an offshore bank pled guilty to conspiracy to defraud the United States by intentionally circumventing the requirements of the Foreign Account Tax Compliance Act ("FATCA"). His guilty...
United States
20 Sep 2018
3
Proposed Treasury Regulations Provide Details On U.S. Tax Reform's Transition Tax
On August 1, 2018, proposed regulations under recently enacted section 965 of the Internal Revenue Code were released.
United States
22 Aug 2018
4
Australia Raises Capital Gains Withholding Rate For Foreign Residents In Real Estate Transactions
From 1 July 2017, the withholding rate that a buyer must pay to the Australian Tax Office on purchase of real estate assets from a foreign resident seller increased from 10 percent to 12.5 percent.
Australia
24 Aug 2017
5
French Tax Update - Recent Case Law And Other Noteworthy Publications
Literally "not twice in the same," non bis in idem is basically a legal doctrine whereby no legal action can be initiated twice for the same course of action.
France
5 Feb 2016
6
French Tax Update - French Finance Bills
This first French Tax Update for 2016 contains an overview of the main provisions proposed by the Finance Bill for 2016 and the Amending Finance Bill for 2015.
France
7 Jan 2016
7
French Tax Update - Amending Finance Bill For 2015 And Noteworthy Q4 Case Law
The present French Tax Update contains (i) an overview of the main provisions proposed by the draft amending finance bill for 2015 (loi de finances rectificative pour 2015, 2015 Draft Amending Finance Bill)...
France
9 Dec 2015
8
Indonesia And The Netherlands Sign Protocol To Amend Existing Tax Treaty
The Protocol introduces, among other things, changes to the applicable withholding tax rates in respect of payments of dividends and interest.
Worldwide
9 Sep 2015
9
French Tax Update - Main French Tax Rates For 2015
This special French Tax Update provides an overview of the main tax rates applicable in France.
France
9 Sep 2015
10
Dividend Withholding Tax Exemption And Specific Anti-Abuse Provision
In a recent decision (CAA Versailles, July 8, 2015, n°13VE01079), the Versailles Administrative Court of Appeals (CAA) provided an interesting illustration of the operation of the specific anti-abuse provision...
France
21 Aug 2015
11
Advocate General Opines In ECJ Case Targeting Dividend Withholding Tax
Please see our Update for July 2014 for further details on the facts and legal background of this case involving a French taxpayer who was trading in Dutch equities derivatives.
France
21 Aug 2015
12
Scope Of The Former 40 Percent Tax Basis Relief On Dividends - August 2015
Unlike the aforementioned QPC rulings, the Conseil Constitutionnel did not find the provisions of the FTC relating to the taxation of dividends received by individual shareholders fully compliant with the French Constitution.
France
19 Aug 2015
13
French Tax Update - Recently Published Noteworthy Decisions - July 2015
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months.
France
7 Jul 2015
14
Scope Of The Former 40 Percent Tax Basis Relief On Dividends
The 40 percent tax relief on the amount of dividends received has been maintained.
France
4 Jun 2015
15
Corporate Tax Treatment Of Loans Between A French Head Office And A Non-French Branch
A French bank, acting from its head office, had advanced loans to various branches located in China, Philippines, India, Singapore, and Thailand.
France
3 Jun 2015
16
French Tax Update - Early 2015 Noteworthy Case Law And Tax Transparency Package
The actual availability of the tax credit depends on the exact wording of the relevant treaty.
France
10 Apr 2015
17
French Tax Update - Noteworthy Tax Courts Decisions And Draft Macron Law
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron.
France
18 Mar 2015
18
Overview Of Real Estate Investments In Italy
Real estate investments in Italy are mainly carried out via one (or a combination) of the following types of investment vehicles.
Italy
16 Jan 2015
19
French Tax Update - 2015 Finance Law, 2014 Amending Finance Law, And Macron Draft Law
The Finance Law for 2015 and the Amending Finance Law for 2014 have now been enacted by the French Parliament and reviewed by the Constitutional Court.
France
12 Jan 2015
20
Withholding Tax Exemption On Bond Interest Broadened
Law Decree No. 91 of June 24, 2014 has broadened the scope of the withholding tax exemption applicable to eligible nonresident investors on certain debt-like securities.
Italy
13 Oct 2014
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