News & Analysis as of

Corporate Taxes Multinationals

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

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 Impact of Tax Reform on Private Equity

If the past 12 months have taught us anything, it’s that the future is hard to predict. One need only look at the ascendancy of Brexit, President Donald Trump, or even the New England Patriots in the second half of the Super...more

China Tax Newsletter - January / February 2017

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. In the past two months, there are a number of developments in the tax world in the PRC and Hong Kong. In the PRC, the State Administration for Industry and Commerce...more

The U.S. Tax Reform and the Energy Sector

by Hogan Lovells on

President Donald Trump and Republican Congressional leaders have promised a major reform to the U.S. tax code in 2017. This reform, if anything close to these promises, will have significant implications for the energy...more

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

by Latham & Watkins LLP on

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...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

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

Tax reform: Are you ready for the storm?

by Dentons on

You may want to think of tax reform as a pending storm. First, it is sorely needed; it has been a long time since we had the last real one. Second, even though we see storm clouds gathering, we are not exactly sure when it...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

Country by Country: Luxembourg introduces law on country-by-country reporting

by DLA Piper on

On the 13th of December, the Luxembourg parliament voted in favour of a law on country-by-country reporting (CbCR). The conditions for a Luxembourg tax resident company to be subject to CbCR are the following...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

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

by Seyfarth Shaw LLP on

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

UK: when the Diverted Profits Tax and the expanded royalty withholding tax rules interact

by DLA Piper on

Two ways in which the UK government has recently sought to increase the amount of tax payable in the UK by non-resident companies have been to impose a new Diverted Profits Tax (DPT) and to amend its existing 20 percent...more

The Australian Government increases pressure on multinational tax avoidance: Diverted Profits Tax introduced

by DLA Piper on

INTRODUCTION AND OVERVIEW - The Australian Government released draft legislation on 29 November 2016 to implement a UK-style DPT with effect from 1 July 2017. The DPT targets 'significant global entities' (those...more

"Double Trouble": The Kenyan Constitution and DTAs

by Dentons on

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

European Commission publishes an EU corporate tax system

by DLA Piper on

Today the European Commission published three corporate tax directives that potentially will apply in 27 Member States (28 - UK) of the European Union. These corporate tax directives include: the Common Consolidated Tax Base...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Changes to Dutch dividend withholding tax rules

by DLA Piper on

Today, the Dutch Ministry of Finance announced that it intends to introduce two important changes to the Dutch dividend withholding tax rules...more

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