News & Analysis as of

BEPS

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

Brexit Update: UK as a Holding Company Hub

by McDermott Will & Emery on

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

China Tax Newsletter - September / December 2016

by DLA Piper on

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

by Proskauer - Tax Talks on

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

by DLA Piper on

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

by DLA Piper on

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

by Hogan Lovells on

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

by Hogan Lovells on

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?

by Hogan Lovells on

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...

by Dechert LLP on

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

by DLA Piper on

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

by DLA Piper on

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

by DLA Piper on

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

by DLA Piper on

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

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