News & Analysis as of

BEPS

Hong Kong: ground-breaking transfer pricing legislation – key features

by DLA Piper on

The Hong Kong government has gazetted an unprecedented tax legislative amendment – the Inland Revenue (Amendment) (No.6) Bill (Amendment Bill), on December 29, 2017, to meet the international standards promulgated by the...more

Corporate treasurers have their say on 2018 challenges

Corporate treasurers play an increasingly critical role as advisors to their organizations. What are the biggest challenges they see in 2018 and what are the regulations that will most affect their business? ...more

UK Tax Round Up - December 2017

by Proskauer Rose LLP on

Finance (No. 2) Bill 2017-19 - The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more

Lunione europea ha pubblicato la black list dei paradisi fiscali

Il Consiglio Europeo dei ministri dell'economia ha approvato e pubblicato una lista di 17 Paesi considerati paradisi fiscali (c.d. "Black List") e una lista di 47 Paesi che si sono impegnati ad allinearsi e rispettare i...more

2017 in review and what to watch for in 2018

by DLA Piper on

2017 has been a year in which the new Financial Markets Conduct Act (FMCA) regime has started to bed in, following the rush to transition by 1 December 2016. The industry is coming to grips with a "new normal" of statutory...more

Congress Passes Tax Cuts and Jobs Act

On December 20, 2017, the House and Senate approved H.R. 1, the "Tax Cuts and Jobs Act" (the "Act").1 This approval follows reconciliation by a conference committee of the original legislation passed by the House on November...more

Business Tax Reform – Key Provisions

Congress is set to vote on the tax reform bill, entitled the "Tax Cuts and Jobs Act," after resolution in conference committee of the differences between the House and Senate versions of the bill. Here is a quick look at the...more

House and Senate Conference Committee Releases Final Tax Bill

by Hodgson Russ LLP on

On December 15, the final version of the “Tax Cuts and Jobs Act” was released, which reflects a compromise between the House and Senate versions of the tax reform legislation. Republican leaders expect both the House and...more

State Aid in Disguise?—EC Investigates UK Tax Regime

by Jones Day on

The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more

Seventeen Provisions to Watch in the Senate Tax Reform Bill

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

India publishes new rules for master file and CbC reporting

by DLA Piper on

Acting on its commitment to the OECD BEPS Action Plan, India has published the final guidance in relation to the requirements of multinationals to provide master file and country-by-country (CbC) reporting in India. The...more

Technology companies and transfer pricing

by Hogan Lovells on

What is transfer pricing? In basic terms, transfer pricing is the process by which multinational enterprises go about determining what jurisdictions their global profits are booked in. It’s something they have to do in...more

UK Autumn Budget 2017 – the key measures impacting business

by White & Case LLP on

The Chancellor, Philip Hammond, has announced the Autumn Budget 2017. Alongside the headline-grabbing abolition of SDLT for first-time buyers on homes up to £300,000, and on the first £300,000 of properties up to £500,000,...more

Davis Tax Committee report

by Hogan Lovells on

The Davis Tax Committee (the Committee) released a further report on "Tax Administration" on 13 November 2017 as part of the final six reports that were deliverable by the Committee. ...more

The State and Local Tax Implications of Federal Tax Reform

On November 2, 2017, Republicans in the House of Representatives released their much-anticipated tax reform bill (the House Plan). The Tax Cuts and Jobs Act (H.R. 1) proposes numerous changes to the Internal Revenue Code,...more

Base Erosion and Profit Shifting Project implementation in Mauritius

by Dentons on

The Organisation for Economic Co-operation and Development (OECD) is an economic organisation made up of 35 member countries, with the aim of encouraging economic progress and world trade. In 2015, the OECD developed the Base...more

Japan's National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

by DLA Piper on

The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD's Base erosion and profit shifting (BEPS) Action 14 Final...more

UK Tax Round Up - October 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Financial Services Quarterly Report - Third Quarter 2017: Luxembourg Developments

by Dechert LLP on

Luxembourg recently has taken a number of actions in connection with the transposition or implementation of various EU directives and regulations, respectively, into national law. The Luxembourg government deposited a bill of...more

OECD releases reviews on BEPS Action 14

by DLA Piper on

The OECD has released analyses of individual country efforts to improve dispute resolution mechanisms. Belgium, Canada, the Netherlands, Switzerland, the United Kingdom and the United States are the subject of this first...more

Investor-Friendly Tax Treaty Set for Mexico and Spain

by Jones Day on

The Situation: A Tax Treaty developed to avoid double taxation, negotiated between Mexico and Spain in late 2015, was just recently published in the official gazettes of both nations. The new protocols are effective September...more

Hong Kong releases Consultation Report on Measures to Counter Base Erosion and Profit Shifting: key topics

by DLA Piper on

The Hong Kong government, represented by the Financial Services and the Treasury Bureau (FSTB) and the Inland Revenue Department (IRD), has released its Consultation Report on Measures to Counter Base Erosion and Profit...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Introduction of new tax incentives for intellectual property

by Allen & Overy LLP on

The Luxembourg Government has, on 4 August 2017, submitted a bill1 to Parliament for the reintroduction of a regime of taxation of intellectual property (IP) rights in Luxembourg. The new regime is intended to replace the...more

UK Tax Round Up - August 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

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