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Holding Regimes In A New Era - 2021 Edition
We are pleased to present you the 2021 edition of the Loyens & Loeff publication Holding Regimes in a New Era – Comparison of Tax and Non-Tax Aspects of Selected Countries.
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European Commission: ‘Dutch Plans To Buy Out Pig Farmers Are In Accordance With The EU Rules On State Aid'
A Dutch government plan that provides for a voluntary buy-out regime of pig farms for the purpose of environmental protection may be implemented.Loyens & Loeff - Article
US Fund Managers: Clearing The Mist On Luxembourg General Partner And Director Liabilities – New York Office Snippet
US fund managers establishing Luxembourg special limited partnerships face critical decisions about board composition and liability exposure.Loyens & Loeff - Article
Post-Brexit Recognition Of English Insolvency Judgments In Luxembourg And Its Effects On European Restructurings
European distressed debtors and creditors face uncertainty regarding English law-governed debt and, more generally, their overall restructuring strategyLoyens & Loeff - Article
Bill Of Amendment To The Proposed Exit Tax Removing Retro-active Effect
On 26 October 2021, a bill of amendment to the pending bill of law for an exit tax for Dutch dividend withholding tax (DWT)...Loyens & Loeff - Article
Switzerland About To Abolish Its 1% Equity Stamp Tax
Switzerland will hold a referendum vote on 13 February 2022 addressing whether its equity stamp tax of 1% will be abolished.Loyens & Loeff - Article
Permanent Establishments Series #4: Allocation Of Profits If A PE Is Considered Present – New York Office Snippet
When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...Loyens & Loeff - Article
The Impact Of The G7's Pillar Two Statement On U.S.-parented Multinational Groups
Our tax professionals recently contributed an article to Tax Notes International titled "The impact of the G7's Pillar Two statement on U.S.-parented multinational groups."Loyens & Loeff - Article
EU Tax Directives #2: EU ATAD 3 Directive – New York Office Snippet
Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. The topic of this Snippet is the draft EU ATAD 3 directive (the 𝐃𝐢𝐫𝐞𝐜𝐭𝐢𝐯𝐞)...Loyens & Loeff - Article
EU Connect Snippet #5: Europe Connect Priority Roadmap
The European Union's One Europe, One Market Roadmap sets out a comprehensive legislative and policy agenda for 2026-2027, targeting regulatory simplification...Loyens & Loeff - Article
Challenging And Enforcing Arbitration Awards In Luxembourg And Belgium
Luxembourg and Belgium offer robust legal frameworks for arbitration proceedings, with comprehensive procedures for challenging and enforcing arbitral awards. Legal professionals can leverage detailed insights into post-award proceedings, recognition mechanisms, and remedies available through the courts in both jurisdictions.Loyens & Loeff - Article
EU Tax Alert 213
The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarized the highlights of this edition below.Loyens & Loeff - Article
US Fund Managers: Offerings To EU Investors And Exposure To Securitisations: Mind The Pitfalls – New York Office Snippet
US private fund sponsors trend towards the use of Luxembourg access points in their fund complexes to tap into the EU investor market. Such an access point qualifies from an EU regulatory perspective...Loyens & Loeff - Article
ELTIF Snippet Series #10 Expanding Your Investor Base In The UK – The LTAF As A Feeder Into Part 2 UCIs & ELTIFs Explained
Post-Brexit, the Financial Conduct Authority (FCA) introduced the Long-Term Asset Fund (LTAF), a UK-authorised open-ended fund structure which bears several similarities...Loyens & Loeff - Article
US Fund Managers Fundraising In Europe: Should A Separate PPM Be Prepared For The Luxembourg Sleeve? – New York Office Snippet
US fund managers (USFNs) raising capital in Europe often use a Luxembourg special limited partnership (SCSp) as the investor-facing vehicle for European investors within a broader fund complex.Loyens & Loeff - Article
Switching Off AIFMD 2.0 Risk Retention Rules – Transferring Originated Loans Within The Fund's Investment Strategy – New York Office Snippet
Under AIFMD 2.0, the transfer to third parties of loans originated by Luxembourg alternative investment funds (AIFs) managed by an EU alternative investment fund manager (EU AIFM)...Loyens & Loeff - Article
OECD Releases New Pillar Two Guidance, Updated GIR And Framework For Legislative Reviews
The OECD has released new administrative guidance on Pillar Two's Global Anti-Base Erosion (GloBE) Rules, addressing explicitly conditional taxes and QDMTT safe harbour operations. The package includes an updated GloBE Information Return incorporating permanent safe harbours and establishes a peer review framework for assessing whether domestic legislation aligns with international standards.Loyens & Loeff - Article
ESG In Switzerland: Regulatory Developments And Practical Implications
ESG expectations are increasingly shaping the Swiss legal and regulatory landscape, with significant implications for financial institutions and multinational organisations operating in or through Switzerland.Loyens & Loeff - Article
US Fund Sponsors Relying On Rule 506(c): Mind The Impact On EEA Fund Marketing Rules – New York Office Snippet
US securities law allows investment managers (IMs) to raise capital in the US without SEC registration through exemptions...Loyens & Loeff - Article
Australian High Court's PepsiCo Decision: Key Tax Insights From Belgium And The Netherlands
The recent judgment by the Australian High Court in the PepsiCo case has sparked significant interest in international tax circles. At the core of the debate: can a fee for the purchase of goods include...Loyens & Loeff