
Publication
Essential Corporate News – Week ending 11 July 2025
On 1 July 2025, the Quoted Companies Alliance (QCA) published three new board committee guides to accompany the QCA Environmental and Social Guide published in December 2024.
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
On 1 July 2025, the Quoted Companies Alliance (QCA) published three new board committee guides to accompany the QCA Environmental and Social Guide published in December 2024.
Publication
In the two years since our last climate litigation update, the prevalence and variety of global climate litigation around the world has continued to increase.
Publication
Selon un rapport conjoint du Bureau du surintendant des institutions financières (BSIF) et de l’Agence de la consommation en matière financière du Canada (ACFC), environ 70 % des institutions financières fédérales prévoient utiliser l’IA d’ici 2026 .
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