Europe: Tax

The way employers carry out checks will stay the same. However, checks will no longer be limited to employees. Instead, the rules will apply to a much wider range of working arrangements.

Pension funds have long enjoyed a favourable status for UK Inheritance Tax (IHT). Most registered pension schemes are discretionary and outside the scope of UK IHT.

Skatteministeriet og Skatterådet har truffet nye afgørelser om værdiansættelse af udskudt skat ved optionsudnyttelse i ejendomsselskaber samt betingelser for succession ved aktiv udlejningsvirksomhed.

Skatteministeriet og Skatterådet har truffet nye afgørelser om værdiansættelse af udskudt skat ved optionsudnyttelse i ejendomsselskaber samt betingelser for succession ved aktiv udlejningsvirksomhed.

The Netherlands employs anti-loss trafficking rules to prevent companies from trading carry-forward tax losses, with the Supreme Court recently extending these restrictions to unrealised losses. Understanding how ownership changes, activity reductions, and post-closing restructurings affect access to tax attributes is crucial for US multinational enterprises pricing acquisitions of Dutch targets.

The OECD's November 2025 updated Commentary on Article 5 of the Model Tax Convention introduces groundbreaking guidance on when cross-border remote working arrangements and home offices may create permanent...

The French Supreme Court has clarified how to interpret the concept of a legal entity whose assets consist principally of immovable property when this concept is not defined in an applicable tax treaty. The decision addresses whether interests held by family members and indirect holdings through intermediary entities must be considered when determining if a company falls within the scope of real estate provisions in tax treaties.

Skatteministeriet og Skatterådet har truffet nye afgørelser om værdiansættelse af udskudt skat ved optionsudnyttelse i ejendomsselskaber samt betingelser for succession ved aktiv udlejningsvirksomhed.

RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.

RPC's Tax Bites delivers monthly updates on critical UK tax developments, including HMRC guidance changes, tribunal decisions on employment status and film partnerships, and evolving compliance requirements. This edition examines landmark cases that clarify the boundaries between employment and self-employment, explores when film production expenditure qualifies for tax relief, and analyzes HMRC's approach to payment reallocation and penalties.

The Upper Tribunal examined whether a limited liability partnership was carrying on a business with a view to profit when loan notes were transferred to it, determining the application of capital gains tax provisions. The case explores the interpretation of 'business' in tax legislation and the application of the Ramsay principle of purposive statutory construction in the context of a tax mitigation arrangement.

IFICI applications in Portugal can be rejected when applicants overlook requirements around qualifying activities, Portuguese-source income, professional roles, qualifications or economic substance. Understanding these risk areas before becoming tax resident can help applicants avoid costly mistakes.