Europe: Tax

The UK Government has launched a consultation proposing significant changes to the withholding tax regime on interest payments to overseas lenders. The proposed reforms would shift from HMRC's current gatekeeping role to a self-assessment system where UK borrowers independently determine treaty relief eligibility, fundamentally altering compliance responsibilities and risk allocation in cross-border lending arrangements.

The OECD has released new administrative guidance on Pillar Two's Global Anti-Base Erosion (GloBE) Rules, addressing explicitly conditional taxes and QDMTT safe harbour operations. The package includes an updated GloBE Information Return incorporating permanent safe harbours and establishes a peer review framework for assessing whether domestic legislation aligns with international standards.

Swedish companies operating in Norway through branches face significant tax challenges when deducting Norwegian pension costs, as Swedish authorities have rejected these deductions due to insufficient insurance elements.

L'Administration fiscale a actualisé sa doctrine sur le dispositif Dutreil suite à la réforme de la loi de finances pour 2026, qui allonge l'engagement de conservation et exclut certains biens "somptuaires". Cette mise à jour clarifie plusieurs points d'application mais laisse subsister des zones d'ombre, notamment sur le critère d'exclusivité d'affectation des actifs et le traitement des dettes afférentes aux biens exclus.

Family businesses face unique challenges when it comes to succession planning, from navigating complex family dynamics to ensuring business continuity across generations. Drawing on experience with high-profile disputes and successful transitions, this article explores practical strategies for avoiding conflicts and securing your family business's future through proactive planning, transparency, and professional guidance.

El Tribunal Supremo examina si las rentas de una herencia yacente deben imputarse fiscalmente a herederos llamados a término antes de que se cumpla dicho plazo y puedan aceptar la herencia. La sentencia analiza la posible doble imposición cuando estas ganancias patrimoniales se gravan primero en IRPF y posteriormente en el impuesto de sucesiones al cumplirse el término testamentario.

The Court of Appeal has delivered a landmark judgment that fundamentally changes the landscape for business rates mitigation strategies involving empty commercial properties. The ruling scrutinizes arrangements where property owners grant short-term leases to rates mitigation companies that place worthless items on premises solely to trigger empty property relief, applying the 'Ramsay principle' to determine whether such transactions serve genuine commercial purposes beyond tax avoidance. This decision over

Denmark has introduced significant changes to its property valuation and taxation regime through Act No. 615, extending indexed property valuations through 2027 and creating a unified category for agricultural, forest and nature properties. The legislation includes new binding ruling procedures, land tax relief for roof apartment projects, and extended deadlines for reassessments, fundamentally reshaping how property owners and investors navigate Danish real estate taxation.

Buying property in Spain feels, to most UK buyers, more familiar than it is. The process has a similar shape to a UK purchase. You find a property, agree a price, sign contracts, then complete. The legal framework underneath that shape, however, is different in ways that matter, and the points at which things go wrong are rarely the obvious ones. They tend to be structural issues that were not identified before commitment was made, and that become significantly harder to resolve once they have arisen.

Turkey introduces new withholding tax rates on investment fund gains for corporate investors, raising the rate to 10% for money market funds while maintaining 0% for other fund types. The regulation establishes different treatment for gains acquired before and after September 5, 2026, with specific calculation methods for the transition period.

The Supreme Court has clarified how to determine whether LLP members have "significant influence" for tax purposes, establishing that qualifying influence must derive from legally enforceable rights traceable to the LLP agreement rather than informal power or strong performance. This landmark ruling provides a structured framework for assessing member status prospectively...

Transfer pricing often first appears to be an accounting question. The legal position matters just as much. A payment between companies in the same group may be recorded correctly in the accounts and still need to be tested against the terms independent parties would have agreed.