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  09/09/2024

  United Kingdom

  UK Tax Disputes Digest (Summer 2024)

  Welcome to the Summer 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including the latest...

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  28/08/2024

  Ukraine

  Ukraine launches large-scale privatisation

  The State Property Fund of Ukraine (SPFU) has unveiled the Large Privatisation-2024 project, an ambitious initiative to attract strategic investors and stimulate economic growth through the privatisation of state-owned assets.Following the success of small-scale privatisation efforts, this initiative is a key element of Ukraine’s broader economic reform strategy. It aims to enhance transparency, improve efficiency, and drive foreign investment into the country. The key highlights of the privatisation effort are as follows:Top assets for privatisation. The programme has identified several...

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  06/08/2024

  Hungría

  EU Commission finetunes the Foreign Subsidies Regulation: insights into the latest Guidance

  On 26 July 2024, the European Commission released a staff working document that clarifies the Commission’s substantive test under the Foreign Subsidies Regulation (FSR). This document serves as a valuable supplementary resource to FSR case-law and provides insight into how the Commission will conduct FSR assessments. Although this document is not binding, it may also prove highly beneficial for companies in evaluating and managing FSR risks.What are FSR procedures?The preamble to the FSR states that existing EU instruments do not address distortions caused by foreign aid, prompting the Commission...

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  26/07/2024

  Italia

  Ruling no. 148/2024: tax exemption for dividends and capital gains realized by foreign funds - requirements

  The Italian Tax Authority (“ITA”), with the ruling no. 148/2024 published on July 11, 2024, confirms the application of the exemption regime - introduced by Article 1, paragraph 633, Law No. 178/2020 ("Budget Law 2021") - for Italian source dividends as well as capital gains deriving from the disposal of qualified participations realized by foreign investment funds, as better defined below.First of all, it should be recalled that the aforementioned Budget Law 2021 introduced the exemption regime for Italian-source income, consisting of dividends and capital gains (or capital losses)...

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  21/06/2024

  Italy

  Italian Supreme Court Upholds OECD Transfer Pricing Rules

  The decisions of the Italian Supreme Court nos. 10577/2024 and 10499/2024 (concerning the same case for corporate income tax and regional income tax purposes) confirm important principles regarding transfer pricing transactions between associated companies.Firstly, the approach taken in the previous decision of the Italian Supreme Court no. 15668/2022 (available here) is confirmed with regard to the relevance of the arm’s length principle set forth by Article 9 of the OECD Model Tax Convention and included in Article 110, par. 7 of the Italian Income Tax Code.Moreover, the principle that,...

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  06/06/2024

  CEE

  Gambling Regulation: Opportunities and Challenges 2024

  The gambling sector in Central and Eastern Europe (CEE) is constantly evolving, driven by regulatory changes that are shaping the industry. CMS is excited to present the third edition of our comprehensive expert guide, the CEE Guide to Gambling Laws, which explores the legal landscape of gambling and offers expert advice on regulatory matters and recent developments.Gambling Regulation: Opportunities and ChallengesThe liberalisation of gambling regulations is creating new opportunities in some jurisdictions, while others are imposing stricter legislative controls, narrowing the legal avenues for...

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