EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE -
On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more
6/6/2022
/ American Bar Association (ABA) ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Taxes ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
EU ,
European Commission ,
GILTI tax ,
Investigations ,
Member State ,
Model Rules ,
OECD ,
Pillar 2 ,
Sustainability ,
Tax Rates ,
White Collar Crimes
INTRODUCTION TO US TAXATION OF NFTS -
Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more
WHAT IS THE AIM OF PILLAR 2 RULES?
The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more
The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more
The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more
2/11/2020
/ Appeals ,
Audits ,
BEPS ,
Corporate Counsel ,
Corporate Taxes ,
Criminal Prosecution ,
EU ,
Foreign Subsidiaries ,
France ,
Google ,
Ireland ,
Non-Prosecution Agreements ,
OECD ,
Popular ,
Principal Place of Business ,
Search & Seizure ,
Settlement ,
Tax Authority ,
Tax Evasion ,
Tax Treaty ,
Value-Added Tax (VAT)
The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
7/15/2015
/ Corporate Taxes ,
Dividends ,
Double Taxation ,
EU ,
France ,
Germany ,
HMRC ,
Income Taxes ,
Italy ,
Multinationals ,
Mutual Agreement Procedure ,
Required Documentation ,
Subsidiaries ,
Tax Avoidance ,
Tax Credits ,
Tax Penalties ,
Tax Refunds ,
Taxable Distributions ,
Transfer Pricing ,
Treaty on the Functioning of the European Union (TFEU) ,
UK
EU resident individual taxpayers who have paid French social taxes (contribution sociale généralisée (CSG), contribution au remboursement de la dette sociale (CRDS) and prélèvements sociaux) on France-originating real estate...more
Scope of The 3 Per Cent Tax -
The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more
The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more
France’s list of non-cooperative states and territories published in 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru and, effective from 1 January 2014, Jersey, Bermuda and the British Virgin...more
France’s non-cooperative states and territories list for 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru, Jersey, Bermuda and the British Virgin Islands (BVI). The tax consequences related to...more