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We are highly experienced in structuring and executing corporate transactions. Our tax teams advise in relation to some of the world's largest and most complex M&A and corporate finance transactions.

On November 2, 2011, the Internal Revenue Service ("IRS") released a set of proposed regulations (the "Regulations") under Section 892 of the Internal Revenue Code ("Section 892"), which exempts certain investment income earned by...

The Italian tax authorities have just released additional guidelines clarifying several open points on the application of the new, broader, CFC legislation. The guidelines are very welcome as Italian parent companies of foreign affected subsidiaries are currently...

The Italian Government is opening a consultation process on proposed amendments to the secondary legislation governing investment funds. The consultation period closes on Friday 23 April 2011.The proposed amendments to the secondary legislation are meant to...

We are pleased to provide you with the latest edition of our Luxembourg Legal Update. The newsletter provides a compact summary and guidance on the new legal issues which may impact your business, particularly in relation to banking, finance, capital markets,...

The double tax treaty  between Luxembourg and Monaco signed on 27 July 2009 has come into force on 3 May 2010 further to the exchange of instruments of ratification by each of the contracting countries, and applies (i) from 1 January 2011 for taxes withheld...

On 8 April 2011 the Luxembourg direct tax authorities issued Circular L.I.R. 164/2 bis (Circular Bis), which clarifies the conditions for application of a previous circular of 28 January 2011 (the Initial Circular) relating to the tax treatment of intra-group financing...

The current Belgian budgetary negotiations could lead to a number of tax measures likely to result in increased fiscal pressure for companies and individuals. The attached client briefing analyses the most important anticipated tax measures compared with the...

The Netherlands is considered one of the best holding jurisdictions in view of its tax system, including a full exemption on income and capital gains derived from subsidiaries, its extensive tax treaty and investment treaty network, its flexible corporate laws...

George Osborne, the UK Chancellor of the Exchequer, delivered his "Budget for growth" today. Business will welcome a number of the new measures: additional cuts in the rate of corporation tax, the increase in the lifetime limit for entrepreneurs' relief...