New securities transfer tax risks in M&A transactions

On 22 December 2021, the European Commission published a proposal for a Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. This is the second action point of the European Commission’s new tax concept, Business in Europe: Framework for Income Taxation (BEFIT – more details: here). […]

A proposal for a new EU Directive to combat “shell entities” for tax purposes

While the abolition of the securities transfer tax has been ┬ádiscussed on various occasions over the last couple of years, aiming at a tax relief, two court decisions in 2021 led the practice in the opposite direction. After the Federal Supreme Court seemingly expanded the concept of intermediation with a new interpretation earlier this year, […]

New securities transfer tax risks in M&A transactions

While the abolition of the securities transfer tax has been  discussed on various occasions over the last couple of years, aiming at a tax relief, two court decisions in 2021 led the practice in the opposite direction. After the Federal Supreme Court seemingly expanded the concept of intermediation with a new interpretation earlier this year, […]