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Organization for Economic Co-operation and Development International Tax Issues

Conyers

Economic Substance Regime Overview

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The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more

Walkers

Guernsey announces further details of OECD Pillar Two implementation

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Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more

Jones Day

Dispute Resolution Under OECD’s “Pillar Two” 15% Global Minimum Tax Remains Unclear

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In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more

A&O Shearman

Amount B or not to be? The OECD’s Pillar One Amount B report

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The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

Conyers

Guiding Captives Through Global Developments

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Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Conyers

British Virgin Islands Removed from EU Tax Blacklist

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Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

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More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Cadwalader, Wickersham & Taft LLP

Over the Horizon

The resounding theme for the 2023 G20 summit, held on 9th and 10th September in India, has been “Vasudhaiva Kutumbakam” – an ancient Sanskrit phrase meaning “the world is one family.” The term perfectly juxtaposes...more

Alston & Bird

Seeking Shelter in Your International Tax Safe Harbors, Even if They Are Temporary

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Our International Tax Group provides an overview of a pair of safe harbors the Organisation for Economic Cooperation and Development has provided for large multinational enterprises during the transition to the Pillar 2...more

Walkers

Guernsey Guide: legal, regulatory, transparency and supervisory framework

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This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

Ius Laboris

Telework from abroad: tax consequences for employers?

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As employers face growing calls to allow employees to ‘work from anywhere’, they should also consider the possible tax consequences of inadvertently creating a permanent establishment in another country. But what counts as...more

A&O Shearman

OECD Pillar Talk: Pillar Two looming; Pillar One one step closer

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European summer might well be in full swing, but that has not stopped the OECD from pushing ahead with the implementation of its Two-Pillar reforms to international taxation. (For further background on the two Pillars, see...more

A&O Shearman

UK considers changes to rules on transfer pricing, permanent establishments and diverted profits tax

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HMRC has published a consultation paper anticipating reforms to the UK’s rules on transfer pricing, permanent establishments and diverted profits tax. This is a wide-ranging review and it may be that its constituent parts...more

A&O Shearman

UK moves closer to a Pillar Two reality

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The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more

Hogan Lovells

New tax obligations for platform operators as Spain transposes DAC7

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Pursuant to the transposition in Spain of the Council Directive (EU) 2021/514 of 22 March 2021 (so-called “DAC7”) and the implementation of the Model Rules for Reporting by Platform Operators developed by the OECD/G20 BEPS...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Exploring Potential Investor-State Treaty Challenges to the OECD’s Pillar Two Model Tax Rules

Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more

Cadwalader, Wickersham & Taft LLP

EU List of Non-Cooperative Jurisdictions Expanded

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

Proskauer Rose LLP

UK Tax Round Up - February 2023

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VAT incurred on corporate advisory fees not recoverable - In Ince Gordon Dadds LLP v HMRC, the First-tier Tribunal (FTT) has decided that Ince Gordon Dadds LLP (formerly Culver Holdings Limited and the taxpayer) (Culver)...more

Cadwalader, Wickersham & Taft LLP

UK Government Finalises Mandatory Disclosure Rules

The UK Government has published the final version of regulations on 17 January 2023 that will give effect to the UK’s mandatory disclosure rules (“UK MDR”). The International Tax Enforcement (Disclosable Arrangements)...more

A&O Shearman

OECD Pillars: Full steam ahead

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2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Court of Justice Faults European Commission for Expansive Interpretation of State Aid in Tax Rulings

On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more

Stikeman Elliott LLP

Reviewing the 2022 Fall Economic Statement and Other Announcements

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The past week was a busy one for Canada’s Department of Finance (“Finance”). On November 3, 2022, Finance released its 2022 Fall Economic Statement (the “Fall Economic Statement”) and the following day, it introduced Bill...more

Freeman Law

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

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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

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