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Articles by Howard Mayers
Italy’s Investment Management Exemption Avoids Foreign PE Risk
Italy’s Investment Management Exemption regime will help foreign investment vehicles avoid PE risk and attract non-resident investors to Italy, say CMS practitioners. One of the reasons why jurisdictions attract non-resident investors is the ability to appoint locally-based investment managers without creating a tax risk for themselves. Very few tax authorities are committed to securing this environment by offering the investment manager exemption.
New Investment Management Exemption regime in Italy - Scope and comparative aspects with the United Kingdom, Germany and France
New Investment Management Exemption regime in Italy - Scope and comparative aspects with the United Kingdom, Germany and France 16/08/2024 Italy recently introduced an Investment Management Exemption regime (IME) which provides a protective framework to ensure that foreign investment vehicles (and directly or indirectly controlled entities) do not trigger a permanent establishment (“PE”) where...
The impact of Pillar Two and the BEPS Actions on finance transactions
10/08/2023 Increasing interest rates, inflationary costs and the threat of restricted growth (or even recession) continue to add pressure on borrowers. Those pressures, combined with the lower headroom on financial covenants since higher interest rates have taken hold, will... Read more
The impact of Pillar Two and the BEPS Actions on finance transactions
Increasing interest rates, inflationary costs and the threat of restricted growth (or even recession) continue to add pressure on borrowers. Those pressures, combined with the lower headroom on financial covenants since higher interest rates have taken hold, will mean a number of financing transactions will be under stress. That stress can be further exacerbated if there is a risk of additional tax exposure materialising, particularly in highly structured transactions.
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