Podcast: Credit Funds: Withholding Tax on European Investments
Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more
The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more
Transactions within a corporate group can sometimes achieve reduction of tax obligations, regardless of whether or how much such result was intended. One typical way observed is to extend an international intra-group loan by...more
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more
On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share...more
On Friday October 8, 2021, the Organization for Economic Cooperation and Development (OECD) announced that 136 Nations, including the United States and the rest of the G20, have signed on to the OECD/G20 Inclusive Framework...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more
Tras la culminación del proyecto Erosión de la Base Desplazamiento de Beneficios (Base Erosion Profit Shifting o BEPS) en 2017, proyecto creado para combatir la erosión de la base gravable y estrategias para la transferencia...more
It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more
Driven by ever-advancing technologies, today’s multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, especially...more
Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more
In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more
Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
The Base Erosion and Profit Shifting (BEPS) Project of the OECD was launched with the publication of the OECD BEPS Action Plan in 2013. The BEPS Project comprised various "Actions" aiming to fight tax avoidance strategies...more
Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more
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
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
Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more
Rules of the (International) Road - An Overview - Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally,...more
For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more
International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more