Publication
Arbitration trends in the Middle East: What to expect in 2024 and beyond
The last several years have seen rapid growth in the Middle East.
Global | Publication | May 11, 2016
On March 30, 2016, the Italian Tax Authorities issued Circular Letter no. 6 (“Letter 6”), which clarifies issues related to the structure of certain acquisitions, in particular those involving investments by private equity funds. The clarifications are based on para. 1.64 sbq. of OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010.
Letter 6 also indicates the criteria by which the Italian Tax Authorities might assess shareholders’ loans as equity contributions, thereby challenging the deduction of passive interests. According to the Italian Tax Authorities, a shareholders’ loan might be qualified as an equity contribution in the following instances:
In any event, the re-characterization of a shareholders’ loan as an equity contribution will be determined on a case by case basis, following evaluation of the factual background of the case under investigation. The Authorities will scrutinize, in particular, whether the circumstance materially differs from a transaction involving third parties. In that case, the Authorities point out that the relevant assessment will also affect the notional interest deduction mechanism and the applicability of withholding taxes on dividends (instead of on interests).
Letter 6 refers not only to investment structures which will be set up in the future, but also those already existing. Penalties for non-compliance, however, will only be applied to transactions effectuated after March 30, 2016.
Publication
The last several years have seen rapid growth in the Middle East.
Publication
On May 14, 2024, Lena Haffner, Innovation Lead Germany at Norton Rose Fulbright, shared her insights on “How do you make a law firm AI ready?" at Legal Revolution 2024, one of Europe’s leading conferences in legal innovation and technology. Her lecture focused on developing a comprehensive roadmap for integrating AI into law firms, emphasizing the importance of developing a robust AI strategy and fostering an innovation-ready culture. Key topics covered in the lecture included strategic planning, skills development, multidisciplinary teamwork, and strong AI governance.
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