Tag Archives: Dividend

Italy’s Regional Tax Court Denies Dividend Withholding Tax Exemption In the Absence Of Actual Taxation In the Country of Residence

By way of ruling n. 55/6/2019 filed on January 21, 2019, the Regional Tax Court of Abruzzo held that no withholding tax exemption under the EU Parent-Subsidiary Directive applies, unless the EU parent company proves that it has been “materially … Continue reading

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The Payoff From California’s “Data Dividend” Must Be Stronger Privacy Laws

California Governor Gavin Newsom, in his first State of the State Address, called for a “Data Dividend” (what some are calling a “digital dividend”) from big tech. It’s not yet clear what form this dividend will take. We agree with … Continue reading

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No Brexit dividend for authors

In the Public Lending Right Scheme 1982 (Amendment) (EU Exit) Regulations 2018 which were published on 13 August (they have not yet been laid before Parliament), the Government has paved the way for public lending right to carry on unchanged after the … Continue reading

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Actual Taxation Required For Dividend Withholding Tax Relief Under EU Parent Subsidiary Directive, Tax Treaty

The Italian Supreme Court with its ruling n. 25264 of October 25, 2017 (Cassazione n. 25264 of 10-25-2017) held that actual payment of the corporate income tax in the parent company’s home jurisdiction is required for the parent company to … Continue reading

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The deemed dividend dilemma: structuring your cross-border credit support

We frequently act as Canadian counsel to lenders and borrowers in cross-border transactions where credit support is provided to a US parent company by one or more of its Canadian subsidiaries. In structuring the deal, a considerable amount of time … Continue reading

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