Article

Substance requirements: an international overview

Published Date

Oct 12, 2023

Authored by

Tax substance is a crucial factor for cross-border investment structures, especially in light of increased scrutiny and transparency from tax authorities and regulators. Are your cross-border structures resilient to tax substance challenges?

Our tax experts across A&O share their analysis with key insights on substance indicators, risks and guidelines from various jurisdictions.

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Substance requirements an international overview

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This content was originally published by Allen & Overy before the A&O Shearman merger

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About the
authors

Patrick Smet

Partner

Brussels

His work covers a wide range of tax matters, including tax dispute resolution, M&A tax, financial tax, M&A tax, private equity ...

Charles del Valle

Partner

Paris

He has extensive experience in the specific field of private equity, acting mainly for investment funds and also for manag...

Jens Denninger

Senior Associate

Munich

Dr Jens Denninger advises on all aspects of national and international corporate tax law, including in particular transaction-specif...

Francesco Guelfi

Partner

Milan

He focuses on banking and capital markets transactions, including syndicated loans, acquisition finance, real estate finance, project f...

Julien Frahi

Junior Associate

Luxembourg

During this secondment, Julien is advising on a wide range of regulatory matters, mainly related to investment funds (including AIFM...

Maciej Kulawik

Counsel

Warsaw

His particular fields of tax expertise are taxation of financial transactions and withholding tax. As an attorney-at-law he represents ...

Substance requirements: an international overview