By Loyens & Loeff On 20 December 2017, the Court of Justice of the European Union (CJEU) issued its judgment in joined cases Deister Holding AG (C-504/16) and Juhler Holding A/S (C-613/16) v Bundeszentralamt für Steuern. In this ground breaking judgment, the CJEU confirmed that the German anti-abuse provision for withholding tax relief for dividends paid by a German company to certain parent companies resident in another EU member state is too general. Therefore that provision is incompatible with the EU...

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By David M. Kaplan | Partner| 215.981.4620 | Pepper Hamilton The Tax Cuts and Jobs Act (TCJA) will make major changes to the $1 million limit on deductible compensation contained in Section 162(m) of the Internal Revenue Code. Section 162(m) limits the tax deduction available to public companies for compensation paid to top executives to $1 million per year, per executive. However, the law contains significant exemptions, including exemptions for compensation that is performance-based or paid after termination. These exemptions...

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By Jean-Marc Ueberecken and Philippe Wery | Arendt & Medernach Arendt & Medernach is pleased to announce the launch of Arendt Business Advisory, a management consulting and advisory practice which extends our service offer to include strategic, financial and economic insight.  Arendt Business Advisory provides decision-makers with tailored advice linking strategy, corporate finance and operational excellence, with proven field experience to make change happen in private and public organisations and answer executives’ main concerns.ABA advises small and medium-sized businesses, local and...

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By Stout   In recent years, fairness opinions have played an increasingly important role in M&A and related corporate transactions, providing critical information and helping to support a board's decision of whether to move forward (or not) with a transaction. The number and type of providers offering financial opinions has also grown significantly to include a broad range of investment banks, independent business appraisers, accounting firms, and consulting firms. Sorting through the range of providers is only one of the...

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By DS-Concept DS-Concept is pleased to announce that it has provided a €100,000 post shipment finance facility to an international meat trader selling to buyers from Bulgaria, Czech Republic, and Canada. The company, based in the US, is using the facility to increase sales and extend payment terms with European buyers, a move that will help it attract new business. Talks of the facility manifested at a time when the client was experiencing low liquidity and was not able to...

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By Loyens & Loeff On 15 December 2017, the Dutch Supreme Court ruled that two Dutch resident companies with a common Israeli corporate shareholder cannot form a sister fiscal unity based on the non-discrimination clause in the Dutch-Israeli tax treaty. Pursuant to this non-discrimination clause, a Dutch resident company that is held by an Israeli corporate shareholder may not be subject to any taxation, or any requirement connected therewith, in the Netherlands, that is other or more burdensome compared to other...

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