Publication
UK Carbon Border Adjustment Mechanism: how will it work?
In February, we reported on the Department of Energy Security and Net Zero’s confirmation that a UK Carbon Border Adjustment Mechanism (CBAM) would be bought into force by 2027
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
In February, we reported on the Department of Energy Security and Net Zero’s confirmation that a UK Carbon Border Adjustment Mechanism (CBAM) would be bought into force by 2027
Publication
International financial markets have started to show significant interest in nature and biodiversity. Whilst climate change and greenhouse gas emissions have made the headlines in recent years, there has been much less focus on their equally important counterparts, nature and biodiversity. However, that has started to change.
Publication
In April 2024, the UK Government published details of its sustainable aviation fuel mandate (the UK SAF Mandate) and launched a consultation on proposals for a revenue certainty mechanism to support UK sustainable aviation fuel (SAF) production.
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