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Banks and non-bank lenders that securitise loans or transfer them to special purpose vehicles will recognise the model: the loans are transferred to a special purpose vehicle (SPV) or a refinancing vehicle, while the actual customer-facing servicing (instalment calculations, interest rate adjustments, dunning) remains with the original lender, who receives a separate fee for this service.

Two separate recent developments affect German withholding tax (“WHT”) on dividends paid to US shareholders by German subsidiaries. Both arise where a hybrid entity is involved, i.e., where a company is treated as a tax-opaque corporation in one country and as tax-transparent in the other country.

Following the German Federal Fiscal Court's landmark decisions in March 2024, foreign investment funds are, in principle, entitled to a refund of German withholding tax levied on dividends during the period from 2004 to 2017 where the taxation infringed Article 63 TFEU (Free Movement of Capital).

The reform proposed by the Finnish Government serves two main purposes: aligning Finnish law with EU law and removing tax barriers that have so far prevented European Long-Term Investment Funds (ELTIFs), an EU fund category aimed at channeling capital into long-term projects, from being set up in Finland.

On 24 June 2026, the Supreme Administrative Court of Finland (SAC), in decision SAC 2026:50, confirmed that a Luxembourg UCITS sub-fund was not a controlled foreign company (CFC) of its Finnish institutional investor, despite the Luxembourg manager having outsourced portfolio execution to a UK group affiliate.

China has released landmark tax rules targeting offshore trusts, ending long‑term tax “planning” for high‑net‑worth individuals by imposing Chinese Individual Income Tax (IIT) across the full offshore‑trust lifecycle.