On 4 October 2024, the Court of Justice of the European Union (CJEU) ruled that the Dutch interest deduction limitation rule of Article 10a Corporate Income Tax Act 1969 (CITA) is not in breach of EU law...

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.

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...

Under an EU marketing passport, US private fund managers can market their unregulated Luxembourg alternative investment funds (AIF) to EU retail investors that pass a suitability test.

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...

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...

When launching a Luxembourg ELTIF, selecting the appropriate legal form is a critical first step. While the Luxembourg société en commandite spéciale (SCSp)...

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.

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)...

Setting up an office in Luxembourg offers strategic advantages for US fund managers to access EU capital markets.

Following our earlier newsflash on the European Commission indicating that it might withdraw the Green Claims Directive, recent developments show that the proposal is still formally in place.

Dutch tax regulations concerning energy, sustainability and climate are constantly evolving. This publication provides an up-to-date overview of the most significant developments.

The new subsidy module "Flexible electricity consumption" was introduced on 1 April in the amended national subsidy regulations...

The Dutch Ministry of Finance (Ministerie van Financiën) has launched a public consultation on the draft bill to implement the revised Alternative Investment Fund Managers Directive (AIFMD2) in the Netherlands.

Starting from 1 October 2025, companies acting as policyholders for group insurance policies may be required to obtain a licence from the Netherlands Authority for the Financial Markets (AFM).

The European Court of Justice (ECJ) ruled on 17 October 2024 that a card issuer that facilitates charging sessions for electric vehicles can be regarded to buy and resell the electricity for VAT purposes.

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.

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.

On 3 October 2024, the Swiss Federal Supreme Court issued a new ruling on beneficial ownership in a hedged bonds constellation (refund of interest withholding tax).

US securities law allows investment managers (IMs) to raise capital in the US without SEC registration through exemptions...