Europe

Italy’s Supreme Court rules French holding company has sufficient substance for tax purposes

Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . . 

Europe

Isle of Man ratifies multilateral treaty aimed at tax avoidance

The Isle of Man has become the second nation to ratify a multilateral tax treaty designed to prevent tax avoidance by multinational firms. The Isle of Man follows Austria, depositing its instrument of ratification of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD