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Corporate Taxes International Tax Issues Transfer Pricing

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions

The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more

Mayer Brown

Mise à jour de la doctrine administrative relative aux prix de transfert

Mayer Brown on

À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

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Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Jones Day

JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision

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The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more

McDermott Will & Emery

[Webinar] Novità Fiscali Fine 2020 - January 21st, 3:00 pm - 5:00 pm CET

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Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more

McDermott Will & Emery

[Webinar] Tax News At The End Of 2020 - January 21st, 3:00 pm - 5:00 pm CET

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Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to businesses....more

Proskauer Rose LLP

UK Tax Round Up - December 2020

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COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

White & Case LLP

VPN Appeal: When arm's length value needs to look at the market in which participants deal

White & Case LLP on

On 21 October 2020, the Full Federal Court of Australia (Logan, Colvin and Thawley JJ) handed down its appeal decision in the case of Victoria Power Networks Pty Ltd v Commissioner of Taxation [2020] FCAFC 169. This case was...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

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In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

Proskauer Rose LLP on

UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Womble Bond Dickinson on

OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more

Jones Day

Australian Senate Economics Committee Hands Down Report on Corporate Tax Avoidance

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The Commonwealth Senate Economics Committee (a standing committee composed by members of the upper house of Parliament) handed down its long-awaited final report on corporate tax avoidance in Australia. The final report is...more

Hogan Lovells

Tax newsletter - April 2018

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In this month's issue of our newsletter on tax matters in Poland: What is new and what is planned in the tax regulations: The extended deadline for the submission of transfer pricing documentation – Regulation of the...more

Akin Gump Strauss Hauer & Feld LLP

European Court of Justice: Intercompany Pricing Cannot Be Used For EU Import/Customs Purposes If Subject to Adjustments

• A recent judgment of the European Court of Justice for bars the use of intercompany transfer prices for EU imports and EU customs duty purposes if (as is commonly the case) these are subject to retroactive adjustments. ...more

Jones Day

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

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As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Dechert LLP

Brexit – The UK and International Tax Consequences

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The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

McDermott Will & Emery

India Shows a Way

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Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

Bennett Jones LLP

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

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The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

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