Podcast: Credit Funds: Withholding Tax on European Investments
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
On December 21st, 2015 the IRS proposed Country-by-Country (“CbC”) reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations (including their revenue, number of...more
On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more
A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures. On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more