The In-House Lawyer

Tax avoidance: the current UK approach The coalition government’s focus on combating tax leakage has made tax avoidance a topical issue and in recent years the courts have heard numerous anti-avoidance cases. Sarah Gatley clarifies the current position and outlines regulatory ... Read more	The bank levy: what is it? In the run-up to the 2011 Budget, and subsequently, there have been numerous references in the media to the bank levy (the Levy). But what is it, how has it arisen and is it really ... Read more
Changes to the UK-Germany double taxation convention from a German tax perspective Investment activities between the UK and Germany are substantial. However, until recently, taxpayers resident in these two countries have been encumbered by a rather outdated regime dealing with the avoidance of double t... Read more	Non-doms: a guide to HMRC's consultations  In an attempt to simplify the rules on the taxation of individuals, HM Treasury has produced two consultation documents: one outlining a statutory definition of tax residence, and the other suggesting potential reforms to the ... Read more
Full reform of the controlled foreign companies legislation On 30 June 2011, the government published the long-awaited consultation document on reform of the controlled foreign companies (CFC) legislation. The consultation follows the announcement at Budget 2011 that the government would consult on full ... Read more	Spanish holding companies: a suitable vehicle for investing in Latin American Since its introduction in 1995, the Spanish holding companies' regime, Entidades de Tenencia de Valores Extranjeros (ETVEs), has proven to be an attractive and competitive international tax planning scheme for multinational groups from the EU, ... Read more
France: extension of thin capitalisation rules France introduced thin capitalisation rules in the Finance Bill 2006. The rules were codified under article 212 of the French tax code. However, under the Finance Bill 2011 (article 12 of law no 2010-1657 dated ... Read more	New Italian tax regime for the CIVs industry Law Decree No 225 of 29 December 2010 (the Decree), converted to Law No 10 of 26 February 2011, has drastically changed the Italian tax regime of domestic and Luxembourgish collective investment vehicles (CIVs), other ... Read more
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