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Corporate Tax

19 February 2021
Sophie Reguengo Impact of COVID-19 pandemic on fund manager substance arrangements

Jersey - Ogier

In 2020 the comptroller of revenue issued practical guidance which stated that where a company had to alter its operating practices to compensate for the COVID-19 outbreak, the comptroller would not determine that such company had failed the economic substance test under the Taxation (Companies – Economic Substance) (Jersey) Law 2019. As such, fund managers have had to make a number of adjustments to ordinary business practices in line with this guidance.

Author: Sophie Reguengo
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Kevin Spencer Exxon prevails in $200 million tax penalty case

USA - McDermott Will & Emery

The US District Court for the Northern District of Texas recently ruled in favour of Exxon Mobil Corporation in its battle against the government over tax penalties. Exxon had filed amended returns for its 2006 to 2009 tax years seeking a $1.35 billion tax refund based on a change of character of certain transactions. The government disallowed the refund claims and imposed a $200 million penalty pursuant to Section 6676 of the Internal Revenue Code. Exxon paid the penalty and filed suit for a refund.

Author: Kevin Spencer
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Recent updates

Valery Narezhniy Important changes to taxation of transactions involving property rights transfers

Russia - Gorodissky & Partners

Author: Valery Narezhniy
Fabienne Limacher New capital band: greater flexibility in capitalisation of Swiss companies and necessary changes to tax law

Switzerland - Walder Wyss

Authors: Fabienne Limacher, Maurus Winzap
Emily Haithwaite Economic substance: clarification of COVID-19 concession

Jersey - Ogier

Authors: Emily Haithwaite, Niamh Lalor, Matthew Shaxson, Alex Fisher
Tim Clipstone Economic substance update: COVID-19 concessions, self-managed funds and partnerships

Guernsey - Ogier

Authors: Tim Clipstone, Richard Doyle
Anat Shavit Taxation of investment funds

Israel - Fischer Behar Chen Well Orion & Co

Authors: Anat Shavit, Ronald Lehmann, Ron Sitton, Yuval Peled
Simona Zangrandi Budget Law 2021: tax incentive for business combinations

Italy - Studio Legale e Tributario Biscozzi Nobili Piazza

Authors: Simona Zangrandi, Franco Pozzi
Wendawn Miller-Frazer CESRA: economic substance reporting deadline extension

Bahamas - Lennox Paton

Author: Wendawn Miller-Frazer