Publication
“AI and sustainability - cure or curse?”
While AI can help resolve data issues in sustainable investing, it can create problems such as information breaches and inherent bias in data.
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
While AI can help resolve data issues in sustainable investing, it can create problems such as information breaches and inherent bias in data.
Publication
In this edition of Regulation Around the World we review recent steps that financial services regulatory authorities have taken as regards investment research.
Publication
The proliferation of internet-enabled devices has allowed children to access the internet at an increasingly younger age, often sharing their personal data without fully appreciating the risks and consequences of doing so. Accordingly, organisations that collect children’s personal data online have a shared responsibility to ensure that such personal data is collected with the appropriate consent obtained and is adequately protected, and to allow children to safely participate in the online space.
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