On this episode of "GILTI Conscience," Skadden attorneys David Farhat, Patrick O'Gara, Loren Ponds and Stefane Victor are joined by guest Pascal Saint-Amans, founder and CEO of Saint-Amans Global Advisory and former director...more
On January 5, 2026, the Organisation for Economic Co-operation and Development (OECD) released a long-awaited package of administrative guidance which introduces a number of new safe harbors within the Pillar Two Global...more
1/12/2026
/ Base Erosion Tax ,
BEPS ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cross-Border Transactions ,
Income Taxes ,
International Tax Issues ,
Jurisdiction ,
Multinationals ,
New Guidance ,
New Legislation ,
OECD ,
Pillar 2 ,
Reporting Requirements ,
Safe Harbors ,
SBS Entities ,
Tax Liability ,
Tax Planning
In the November 2025 Budget, the UK government confirmed that His Majesty’s Revenue and Customs (HMRC) will be introducing a “US-style” whistleblower incentive scheme (Scheme) in the UK....more
12/5/2025
/ Department of Justice (DOJ) ,
Enforcement Actions ,
HMRC ,
Internal Controls ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Legislation ,
Proposed Legislation ,
Tax Authority ,
Tax Avoidance ,
Tax Evasion ,
Tax Legislation ,
UK ,
Whistleblower Awards ,
Whistleblowers
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
7/9/2025
/ Corporate Taxes ,
Cross-Border ,
HM Treasury ,
HMRC ,
Intellectual Property Protection ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Planning ,
Taxation ,
Transfer Pricing ,
UK
On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more
On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more