News & Analysis as of

BEPS

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Introduction of new tax incentives for intellectual property

by Allen & Overy LLP on

The Luxembourg Government has, on 4 August 2017, submitted a bill1 to Parliament for the reintroduction of a regime of taxation of intellectual property (IP) rights in Luxembourg. The new regime is intended to replace the...more

UK Tax Round Up - August 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

by DLA Piper on

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as...more

Luxembourg announces new IP tax regime

by DLA Piper on

Luxembourg has announced a new regime that offers a special tax incentive for certain income from intellectual property rights. The bill containing the new IP regime, which is expected to come into effect as of the 2018 tax...more

Branch Report: The Future of Transfer Pricing

by DLA Piper on

The prepared Branch Report is dedicated to Subject 2 of the Congress 'The Future of Transfer Pricing'. It outlines Ukrainian transfer pricing regulations and practices as of the end of 2016, as well as analyses impact of the...more

Japan Legal Update - Volume 27 | July 2017

by Jones Day on

On June 7, 2017, Japan signed the "Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting" ("MLI"). The MLI is a part of the OECD/G20 base erosion and profit-shifting...more

UPDATE: New UK Offences of Failure to Prevent Facilitation of Tax Evasion – looming deadline

by Ropes & Gray LLP on

In May 2016, we published an Alert about UK proposals to introduce new strict liability corporate criminal offences aimed at preventing the facilitation of tax evasion. Andy Howard, Tax partner in the Ropes & Gray London...more

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?

by Bilzin Sumberg on

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

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