BEPS

News & Analysis as of

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

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?

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

Brexit Update: UK as a Holding Company Hub

The United Kingdom is still an attractive location for a holding company, despite the uncertainty over Brexit. ...more

China Tax Newsletter - September / December 2016

Welcome to the latest issue of our Tax Newsletter. In this issue we have covered a number of developments and cases in the PRC and Hong Kong from September to December 2016 which could have legal and tax implications to your...more

BEPS: Update on Action 6 on Treaty Benefits

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

Some good news after all - reforms of the UK substantial shareholding exemption

The substantial shareholding exemption (SSE) in its current form broadly exempts from corporation tax capital gains realised on the disposal of certain substantial shareholdings, provided certain prescriptive conditions are...more

New transfer pricing requirements in Latin America under BEPS

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and...more

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

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime...more

Base erosion and profit shifting - new regulations

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

New Luxembourg country-by-country declaration obligations: What's important?

The law relating to country-by-country ("CbC") declaration obligations (the "Law") was published on 27 December 2016 and entered into force last week. The Law transposes EU Council Directive 2016/881 of 25 May 2016 (the...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

German tax law changes and their impact on multinationals

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

Tax break for infrastructure projects

To implement the G20/OECD base erosion and profit shifting project, the 2016 Budget announced measures limiting tax deductions that companies can claim from their interest expenses (read DLA Piper's earlier client alert on...more

Country by Country: Spain

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

Country by Country: United Kingdom

Introduction - The UK CbC reporting regulations ("The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016") were made on 26 February 2016....more

Country by Country: Germany

In Germany, CbC reporting has not yet been incorporated into domestic laws. However, draft legislation is currently being processed by the legislative bodies (Bundestag and Bundesrat) and is likely to be enacted this year....more

Country by Country: Portugal

The Portuguese CbC reporting rules were approved in March of 2016 by the Portuguese Budget Law for 2016 (“PBL”). The PBL included a provision (article 121.º-A) in the Portuguese Corporate Income Tax Code foreseeing new...more

Country by Country: France

CbC reporting was introduced into French legislation by the Finance Bill 2016. The new provisions, set forth under article 223 quinquies C of the French tax code, are effective for fiscal year ("FY") beginning on or after 1...more

Base erosion and profit shifting: Brazil proposes CbC reporting for multinationals - top points

The Brazilian Federal Revenue (RFB) has released the draft of a proposed Normative Rule (Public Consultation RFB No. 11/2016) regulating the implementation of country-by-country reporting via a CbC Report. The proposed draft...more

BEPS: OECD Releases Multilateral Tax Treaty Convention

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

McDermott International Legal Highlights November 2016

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

Advance pricing agreements: a new era

There has been a significant amount of negative press recently concerning tax rulings and advance pricing agreements (APAs); negativity that has been fuelled by the European Commission's state aid investigations, Lux leaks...more

Recent EU and Luxembourg anti-BEPS developments extending to third countries

EU Commission's ATAD proposal released On 25 October 2016 the EU Commission presented yet another package of corporate tax reforms comprising, inter alia, a proposal on tackling "hybrid mismatches" between the tax...more

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