AI Around the Globe: What to Know in 2024
GILTI Conscience Podcast | Amount B Back in the Spotlight
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
FCPA Compliance Report-Episode 333, Professor Samuel Buell
FCPA Compliance Report-Episode 329, James Koukios
Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more
The UK’s Serious Fraud Office (SFO) published its strategy for 2024–2029 on 18 April 2024, outlining its ambitious plans to become the “pre-eminent specialist, innovative and collaborative agency” in the fight against serious...more
The Serious Fraud Office’s strategy for 2024 to 2029 indicates aspiration to be a more effective agency and to incentivise personnel. On 18 April 2024, the UK’s Serious Fraud Office (SFO) published an ambitious, albeit...more
As announced in the United Kingdom’s Spring Budget for 2024, delivered by the Chancellor of the Exchequer on 6th March, the UK government has published a consultation to seek views on the implementation of the OECD’s flagship...more
This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
The Crypto-Asset Reporting Framework (“CARF”), is the OECD’s flagship tax transparency standard to help combat criminal activity using crypto-assets to evade taxation. The key aspects of the CARF were covered in the article...more
Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen the Chancellor’s Autumn Statement as well as an interesting confirmation from the Court of Appeal on the scope of “arrangements” for capital gains tax...more
A year in review for the ChatGPT (chatbot generative pre-trained transformer) — and a look ahead at the global response to AI & which governance “guardrails” are required. On November 30th, 2023, the world will celebrate...more
Stapled W&I policies and synthetic policies will likely be increasingly common features of E&I transactions, although their feasibility should be assessed case by case. Warranty and indemnity insurance (W&I) is a...more
White & Case Global Antitrust Merger StatPak (WAMS)—the first real-time clearinghouse for global merger notification data—has analyzed merger notifications in reporting jurisdictions around the first half of calendar year...more
Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more
The new securitisation framework will combine three sets of overlapping rules, in an effort to repeal and replace retained EU law in the UK. The missing piece of the puzzle to the UK’s new securitisation framework became...more
United States: The Administration and Congress are taking initial steps to produce legislation to regulate AI and using interim measures, such as the White House’s recently announced voluntary agreement with seven prominent...more
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
Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...more
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
Welcome to June’s edition of our UK Tax Round Up. Several interesting cases have been reported this month, including a range of issues relevant to UK withholding tax on interest being considered in Hargreaves. HMRC has also...more
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