Reto Heuberger


Taxes Committee

The IBA's widely respected and very active Taxes Committee offers its members access to the highest quality technical, practical and professional tax expertise to assist in understanding and finding solutions to international tax issues and concerns.

About the Committee

The Taxes Committee encourages interface between international tax specialists and promotes the building of networks among tax lawyers worldwide to assist them in better serving the interests of their clients. The committee is divided informally into four practice group areas: Income Taxes, Other Taxes, Tax Litigation and Employee Benefits.

Members are encouraged to contribute to the committee newsletter which is published two to three times per year and to present papers at committee conferences and seminars. The committee also offers tax executives a forum, in its Tax Executives group, to exchange expertise and skills with their colleagues in industry on topics of special interest.

Forthcoming conferences and webinars View all conferences and webinars

Tax developments by jurisdiction

The Taxes Committee has published its annual update on tax developments by jurisdiction for 2020. Find out more here

Portugal: cash pooling arrangements and exemption from stamp duty

For more than ten years, multinational enterprise groups operating in Portugal with cash pooling arrangements were faced with the interpretation that such intragroup financing was subject to – and not exempt from – stamp duty. In 2020, the country’s stamp duty code was amended to include a specific exemption applicable to cash pooling arrangements. The question is whether this will work in regard to cross-border arrangements and what remedies may be available.

Released on Jun 10, 2021

Indian Supreme Court decision on characterisation of software payments

The Supreme Court of India has recently rendered its decision in Engineering Analysis Centre of Excellence v The Commission of Income Tax & Anr, finding that the amount paid by resident Indian end-users or distributors to non-resident computer software manufacturers or suppliers, as consideration for the resale or use of computer software, cannot be characterised as ‘royalty’ (that is, the use of copyright in the computer software) under Article 12 of the Tax Treaties.

Released on Jun 02, 2021

Argentina’s tax planning information regime

An increase on the personal assets tax rate in Argentina in 2019, and the creation of a new emergency tax levied on Argentine tax residents and certain nationals’ wealth, encouraged many Argentine families and individuals to restructure their assets in a tax-efficient fashion.

Released on Jun 02, 2021

The not-so-novel Electronic Money Transfer Levy under the Finance Act 2020

A levy on electronic money transfers has been introduced in Nigeria by various amendments to its stamp duty regime. But questions and concerns have been raised as to whether these amendments are good law, particularly the rationale behind the Electronic Money Transfer Levy, its scope, applicability and legality, and how it fits into the existing constitutional framework.

Released on May 28, 2021

Selected distressed and non-distressed deals during the pandemic

The pandemic has seen a change in the landscape of deals, which raises novel issues for advisers. The use of Special Purpose Acquisition Companies (SPACs) has dramatically increased. In an effort to deal with business uncertainty, contingent consideration and rollover equity are becoming a greater component of consideration paid by buyers. Distressed property sales have grown, which raises issues on how to deal with existing debt and limit adverse tax effects for borrowers and lenders alike. Broken deals have increased, raising even more complexity.

Released on May 19, 2021