IBA – the Lugano Convention

This article first appeared on the website of the European Regional Forum of the Legal Practice Division of the International Bar Association, and is reproduced by kind permission of the International Bar Association, London, UK. © International Bar Association.

Danish High Court Decision on International Holding Structure

Derivatives & Financial Instruments - 2012

"The author provides a summary of a recent decision of the Eastern High Court on taxation of dividends at source in the context of an international holding structure. The scope of the summary focusses on the international tax aspect of the case only." (from the table of contents)

Taxation of Basel III-Compliant Instruments

Derivatives & Financial Instruments – 2012

The article comments on the following questions posed by IBFD: 1) Debt/Equity Characterization for Tax Purposes, 2) Deductibility of Coupon for Corporate Income Tax Purposes, 3) Possible Withholding Taxes on Coupons, 4) Recognition of Income and Expense, 5) Tax Treatment of the Conversion versus Write-Down, 6) Stamp Duties/Capital Taxes upon Issue and/or Conversion and 7) Transfer Pricing Consequences of Intercompany Financing.