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Subsidiaries International Tax Issues

Hogan Lovells

Doing business in Italy 2023

Hogan Lovells on

This booklet has been written specifically for business individuals and whilst it may be of interest to their local advisers, such as lawyers or accountants, the information is intended for a wider audience. We cover topics...more

Goodwin

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

Goodwin on

On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more

Proskauer Rose LLP

UK Tax Round Up - June 2019

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Guernsey SPV not resident in the UK - In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer in an important...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

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EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...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

Dorsey & Whitney LLP

China’s Greater Bay Area Puts Hong Kong In The Lead As Super Connector To The World

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China’s open door policy is further opening up to welcome the world for business. The country is now building a landmark megalopolis on its southern coast with the name the “Greater Bay Area” (the “GBA”). ...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Jones Day

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

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On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

Troutman Pepper

Cross-Border Update on Investing and Doing Business in the United States

Troutman Pepper on

In this Issue: - Indian FDI into the United States - Indian Imports into the United States - Formation of US Subsidiaries - Ownership - Liability of Equity Holders - Management ...more

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