News & Analysis as of

BEPS

Private Equity Watch - July 2017

by Ropes & Gray LLP on

With the year half over, it’s still too early to say whether it’s going to be a good one or a difficult one for the private equity market. The July edition of Private Equity Watch provides important perspective on the issues...more

UK Tax Round Up - July 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

Three Fund Issues That Can Unexpectedly Impact Portfolio Company Investments

by Latham & Watkins LLP on

Increasingly complex fund structures and documentation mean that analysing how potential portfolio acquisitions interact with the fund at the top of any deal structure is more important now than ever. Investor Excuse...more

Impact of the Multilateral Instrument on U.S. Taxpayers

by Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

BEPS Update: OECD Multilateral Instrument Signed

by Proskauer - Tax Talks on

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

The Netherlands proposes changes to dividend withholding tax

by DLA Piper on

The Dutch government has released an attractive proposal to fully exempt withholding tax on dividends paid to non-resident shareholders in treaty countries provided certain conditions are met. Many multinational enterprises...more

Leveraged Finance Update - May 2017

by Hogan Lovells on

The search for yield continues...Techniques honed in the more mature US leveraged finance market continue to be imported into European deals and then across to the APAC markets, requiring skillful reworking in some cases to...more

BEPS Update – Germany on the way to limit the tax deductibility of royalties

by Hogan Lovells on

A new legislative approach of the German tax authorities, which had been leaked in December 2016, was passed on Thursday, 27 April 2017, as one of the very last laws of the current Bundestag prior to the elections in...more

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

by DLA Piper on

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the...more

Focus on Tax Strategies & Developments - April 2017

by McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Taxing the Digital Economy: Impending changes to GST in Singapore

by Dentons on

Should digital downloads, streaming services and online purchases from foreign entities be subject to goods and services tax (GST) in Singapore? How about off-premise cloud computing?...more

Expect Focus - International, Spring, March 2017

by Carlton Fields on

Rules of the (International) Road - An Overview - Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally,...more

Tightening the Tax Screws on International IP Structures

by Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

IRS Issues Draft Form and Instructions for Country-by-Country Reports

by Alston & Bird on

Country-by-Country (CbC) reporting is now generally required for the ultimate parent of a U.S. multinational enterprise (MNE) for tax years that begin on or after June 30, 2016. On January 11, 2017, the IRS released a draft...more

Alignment with international standards

by Hogan Lovells on

In March, two notices were published in the Government Gazette prescribing regulations in respect of third party returns and the fixed penalty provisions that will be applicable in instances where there is non-compliance in...more

BEPS – are you affected?

by Ropes & Gray LLP on

Over 100 countries and jurisdictions are collaborating through the OECD to implement measures to tackle base erosion and profit shifting (BEPS). The OECD have set out 15 actions points that aim to equip governments with the...more

German cabinet proposes law bill restricting tax relief for royalties to certain "patent boxes"

On January 25, 2017, the German cabinet has resolved on a law bill dubbed "license barrier" as a reaction to the BEPS initiative. If the bill passes parliament, it will mean that – in principle – tax relief will be...more

DSM webinar highlights tax, competition law, copyright, AVMS and data economy issues for 2017

by Hogan Lovells on

In a February 7, 2017 webinar, the Hogan Lovells Digital Single Market (DSM) team presented its take on new developments for 2017. Peter Watts introduced the session by warning that the loss of the UK voice in EU policy...more

Is Your Customs Compliance BEPS Ready?

by Bennett Jones LLP on

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

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