As a result of the OECD’s BEPS project, there is an increased emphasis on aligning income with substantive activity. Former “double country” structures may no longer be viable due to these BEPS DEMPE requirements.
In this Bottom Line videocast, Eversheds Sutherland (US) Partner Carol Tello and Eversheds Sutherland (International) Partner Alan Connell See more +
As a result of the OECD’s BEPS project, there is an increased emphasis on aligning income with substantive activity. Former “double country” structures may no longer be viable due to these BEPS DEMPE requirements.
In this Bottom Line videocast, Eversheds Sutherland (US) Partner Carol Tello and Eversheds Sutherland (International) Partner Alan Connell discuss:
BEPS effects on US multinational IP structures
impact of US 2017 TCJA on non-US double country structures
Ireland’s IP tax incentives See less -
