Modernising payments and cross-border tax refunds: the implications of US Executive Order 14247
Executive Order (EO) 14247, Modernising Payments To and From America's Bank Account, mandates an end to paper cheques for all United States federal payments, including tax refunds, by 30 September 2025. This article analyses the EO’s impact on expatriate assignees, inbound non-resident taxpayers, multinational employers and non-US individuals or entities with US tax obligations.
Released on Jul 23, 2025
VAT on digital services in Sri Lanka: taxing the cross-border supply of services provided by electronic platforms
This article examines the imposition of VAT on digital services in Sri Lanka, specifically focusing on the supply of services by non-residents via electronic platforms to Sri Lankan consumers. It explores the current legislative framework, implementation challenges and the broader implications on the cross-border supply of digital services.
Released on Jul 18, 2025
It’s a matter of trust: foreign grantor trusts and other trust developments
This panel, at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam on 9 April 2025, discussed foreign grantor trusts in a cross-border context, focusing specifically on cases where US citizen settlors or beneficiaries of a US grantor trust relocate to Europe.
Released on Jul 17, 2025
Reversions: coming back to US-based multinationals
This panel at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam on 10 April 2025 discussed various topics related to multinational companies relocating back to the US and the different push and pull factors.
Released on Jul 17, 2025
Cross-border tax crimes [2025]
This session at the 25th annual IBA/ABA US and Europe Tax Practice Trends Conference in Amsterdam brought together legal experts from various jurisdictions to delve into the complexities of global tax evasion and fraud.
Released on Jul 17, 2025
M&A hot topics (2025)
This conference session at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam in April 2025 discussed a range of hot topics in regard to M&A. The co-chairs and the panellists elaborated on the relevant considerations, tax and non-tax related, relating to the choice of the top company jurisdiction in a merger of equals involving a US group and a non-US group. They also discussed recent trends relating to take-private deals in their respective jurisdictions.
Released on Jul 17, 2025
Luxembourg’s competitive edge: tax reforms to attract talent
Luxembourg continues to consolidate its position as a leading jurisdiction for wealth management and investment structuring, being notably the first fund centre in Europe and second only to the United States globally. This situation is underpinned by a series of legislative reforms, fiscal incentives and regulatory enhancements in the country. In this context, the Minister of Finance, Gilles Roth, has recently underscored the strategic imperative of leveraging current geopolitical and technological developments to reinforce Luxembourg’s global competitiveness.
Released on Jul 16, 2025
Alternative mechanisms for tax dispute resolution in Mexico: a strategic approach amid judicial uncertainty
This article analyses the recent evolution and strategic advantages of alternative mechanisms for tax dispute resolution in Mexico, otherwise known as Mecanismos Alternativos de Solución de Controversias (MASC), mutual agreement procedures (MAPs) and investment treaty arbitration, especially in the context of institutional uncertainty and weakened judicial independence.
Released on Jul 16, 2025
Reviving the stamp tax in Colombia: a step backwards?
This article examines the reinstatement of Colombia’s stamp tax in 2025, questioning whether reviving a historically inefficient and outdated tax is a sound response to a public emergency. It explores the tax’s origins, current scope and broader implications of the change in regard to fiscal policy and legal certainty.
Released on Jul 14, 2025
Cross-border credit assignments and withholding tax in Chile
This article analyses the Chilean tax implications of assigning monetary credits in cross-border transactions. It focuses on the treatment of accrued interest, the effects of the assignment itself and the tax consequences for Chilean assignees, based on the recent interpretation issued by the Chilean Internal Revenue Service (Servicio de Impuestos Internos or SII) in Ruling No 801 of 2024.
Released on Jul 14, 2025
Spain’s changing tax landscape for real estate: key developments and proposals
This article analyses recent and proposed changes to the Spanish real estate tax framework, with a particular focus on the measures implemented in Catalonia and a controversial nationwide draft bill. The key issues discussed include increased transfer taxes, value-added tax (VAT) adjustments and the implications for non-EU investors.
Released on Jul 14, 2025
ABC: AI, Big Data and crypto
This session at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed the future of artificial intelligence and its role in the legal profession, the increased use of Big Data by tax administrations and the taxation of cryptocurrency.
Released on Jul 11, 2025
Recent trends in M&A: the pursuit of capital and financing/restructuring
This panel at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed different cross-border restructuring case studies, both from the inbound and outbound perspective, in terms of the jurisdictions represented by the panel members. A particular focus of the panel was on cross-border mergers, flip transactions and continuations.
Released on Jul 11, 2025
Navigating the stormy seas caused by an onslaught of transfer pricing audits and evolving transfer pricing rubrics
This panel at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed various topics related to transfer pricing audits and dispute resolution. The speakers elaborated on domestic case law and highlighted the recent trends in transfer pricing audits, including challenges in intra-group financing transactions, as well as assertions on embedded royalties by the respective tax authorities.
Released on Jul 11, 2025
Trends in fund structuring: what do we really need to change?
This panel at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed the latest trends in European and United States fund structures, and whether any changes to such structures are warranted in the future.
Released on Jul 11, 2025
Spin-offs and demergers: trends and traps
This session at the 14th Annual IBA Finance & Capital Markets Tax Conference began by noting that the separation of businesses through the use of a demerger has been a trend in the United States in regard to multinational companies with multiple lines of business, due to the pressure from investors to simplify the business. Such separated businesses have either been made public or have been sold to third parties.
Released on Jul 11, 2025
Holding companies: the state of play (2025)
This panel at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed the current status of and developments regarding holding companies globally, with a focus on Ireland, Luxembourg, the Netherlands, Spain, the United Arab Emirates, the United Kingdom and the United States.
Released on Jul 11, 2025
France unveils a new tax regime for management packages: a long-awaited clarification
France’s 2025 Finance Bill introduces a new legal framework, codified under Article 163 bis H of the French General Tax Code, applicable from 15 February 2025. This reform aims to provide clarity by creating a dedicated regime for gains realised on securities acquired or granted in consideration for salaried or management functions (whether by the issuing company, its subsidiaries or the parent entity).
Released on Apr 24, 2025
An overview of Portugal’s new IFICI regime
Following the end of the non-habitual residents (NHR) regime, Portugal has a new tax incentive regime for new residents, which aims to maintain competitiveness in terms of attracting foreign investment and skilled labour by establishing a more favourable tax regime for new residents who meet certain legal requirements.
Released on Apr 24, 2025
France’s Finance Bill for 2025: management package tax reform
The 2025 Finance Bill introduces a new tax regime for management package gains, in continuity with the Conseil d’Etat’s (French Supreme Administrative Court’s) 2021 framework. Gains realised by employees or corporate officers on securities, in connection with their functions, can benefit from the 30 per cent flat tax regime applicable to capital gains within the limit of a ratio equal to three times the equity multiple of the company. The portion exceeding this cap is taxed as salary. The reform clarifies the relevant tax and social security rules, offers greater legal certainty and revives underused instruments, such as preferred shares. Some uncertainties remain, pending further guidance expected from the French tax authorities in May 2025.
Released on Apr 22, 2025
International business reorganisations: tax neutrality and the preservation of Chilean taxing rights under Law 21,713
This article analyses Chile’s Law 21,713, which introduces a specific statute for international business reorganisations. It focuses on three requirements for tax neutrality, namely the production of effects in Chile, the preservation of Chile’s taxing rights and a legitimate business purpose, highlighting new interpretative challenges that could impact the practical application of the new statute.
Released on Apr 22, 2025
Japan considers next steps for VAT on cross-border e-commerce
Japan has finally started to make tangible progress in regard to reforming its value-added tax (VAT) framework to address the challenges brought about by the rapid expansion of cross-border e-commerce. Ongoing discussions are focused in particular on expanding the platform taxation regime to cover the cross-border sale of goods facilitated by online platforms offering fulfilment services, as well as on revising the de minimis import VAT exemption for low-value imported goods.
Released on Apr 22, 2025
Taxing intellectual property for multinationals in Australia: international misalignment?
The Australian Taxation Office (ATO) continues to pay close attention to the taxation of software arrangements. Its views have the potential to cause international misalignment on the way that certain cross-border payments are treated for taxation purposes. This article discusses the ATO’s guidance and a number of developing landmark Australian tax cases covering what constitutes a ‘royalty’.
Released on Apr 13, 2025
Price points and pressure points: multinationals’ transfer pricing in practice during a time of uncertainty
Historically, multinational companies have made operational decisions based primarily on strategic and commercial objectives, with tax professionals later reviewing and refining the resulting structures to ensure tax efficiency. But as major economies, including the US, introduce tariffs and other trade measures, transfer pricing is taking on a more prominent role in shaping business decisions. Although it may not be the central factor, it is becoming an influential consideration in corporate strategy, particularly in regard to a shifting geopolitical landscape.
Released on Apr 13, 2025
Duties and deductions in Canada and the US: the taxing truth about tariffs
The era of tariff-free global trade has long enabled supply chains to operate with stability and predictability. While pricing, supplier selection and customer relationships have always been influenced by various factors, the absence of tariff-related friction established a status quo; one that is now undergoing significant disruption. Another critical factor to evaluate for all Canadian taxpayers impacted by tariffs is their deductibility and the legal grounds based on which such deductions may be claimed.
Released on Apr 13, 2025
Company tax liabilities on ceasing operations in Ethiopia
The notion of taxing a taxpayer when they end their residential status in a country has been an issue for debate among scholars. Countries view the main risk associated with such withdrawal from the jurisdiction as the erosion or complete disappearance of the tax base. Tax is levied in such circumstances in order to provide the relevant tax authority with an opportunity to secure income tax from the departing individual without having to deal with the instant realisation of tax gains or losses. However, the Ethiopian principle in regard to an exit tax is focused on a perceivable gain obtained by the taxpayer upon ceasing residency in the country, which often comes with the disposal of investment assets through a sale or transfer.
Released on Mar 3, 2025
Navigating the intricacies of tax residency in Zambia for corporate entities
This article examines the intricacies surrounding the concept of a ‘place of effective management’ in determining tax residency for foreign corporate entities in Zambia. While Zambia’s Income Tax Act incorporated the concept of a ‘place of effective management’ to align with international practice, the undefined concept creates uncertainty that leaves the concept open to various interpretations. This article further critiques the inadequacy of the guidance provided by Zambia’s tax authority on the concept and compares the concept of a place of effective management with the alternative concept of a ‘head or main office’ in achieving certainty in the determination of the tax residence of corporate bodies.
Released on Jan 8, 2025
International mobility in the United Republic of Tanzania
This article provides a high-level overview of the taxation landscape for entities seeking to establish their business or invest in the United Republic of Tanzania. The current landscape provides for taxes payable or which entities are liable to collect and remit to the tax authorities in the United Republic of Tanzania. The article also discusses the potential tax consequences should an entity seek to exit the country. In this regard, the article examines both voluntary and compulsory exit situations.
Released on Jan 8, 2025
Navigating the UAE’s new corporate tax landscape: key considerations for businesses
The United Arab Emirates (UAE) has historically been known as a tax-friendly jurisdiction, attracting multinational corporations, family offices, investors and individuals to the country. However, in response to evolving global tax policies and a strategic shift away from the reliance on hydrocarbon revenues, the UAE has undertaken significant tax reforms, including the introduction of corporate tax at the federal level in 2023. This article explores the UAE’s evolving corporate tax environment, examining key corporate tax considerations and recent developments that impact businesses operating within the UAE.
Released on Jan 8, 2025
Taxing times ahead: what foreign investors need to know about Bahrain’s tax reform
The Kingdom of Bahrain is undergoing a significant economic transformation as it moves away from its historical reliance on oil and gas reserves. In this respect, Bahrain has strategically diversified its economy, emerging as a prominent business hub within the Gulf Cooperation Council (GCC). This transformation is marked by recent tax reforms, including the introduction of value-added tax (VAT) and a domestic minimum top-up tax, reflecting Bahrain’s aim to establish its long-term economic stability. This article examines the tax environment in Bahrain and the implications for businesses aiming to establish or expand their presence in Bahrain.
Released on Jan 8, 2025