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BEPS Tax Treaty

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

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More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

Holland & Knight LLP

Entra en vigor el Convenio Multilateral para Tratados Tributarios en México

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Se publicó en el Diario Oficial de la Federación (DOF) de México el decreto por el que se promulga el Convenio Multilateral para Implementar las Medidas Relacionadas con los Tratados Fiscales para Prevenir la Erosión de las...more

Holland & Knight LLP

Ratificación del Convenio Multilateral para Tratados Tributarios en México

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Se programó una reunión de trabajo de las Comisiones Unidas de Relaciones Exteriores y de la Secretaria de Hacienda y Crédito Público de México el 6 de octubre de 2022, para la discusión y en su caso aprobación de los...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Freeman Law

International Tax Treaty: Australia

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Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Freeman Law

International Tax Treaty: Mexico

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The world’s most populous Spanish-speaking nation. Mexico is a Federation comprised of 32 states, being Mexico City the capital of the country. The government of Mexico is divided in three branches: the Legislative Branch in...more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

White & Case LLP

Understanding Tax: EU tax challenges for cross border investing and financing

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This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more

McDermott Will & Emery

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

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The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

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

Bennett Jones LLP

Tax Treaty Benefits Threatened as Canada Completes Ratification of OECD's Multilateral Instrument

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On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...more

White & Case LLP

European Real Estate Finance: Recent developments – June 2019

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As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

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On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

Bennett Jones LLP

Business Measures in 2019 Federal Budget

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The 2019 Canadian federal budget was released on March 19, 2019 (Budget Day). As many of the proposals are aimed at investing in Canada’s middle class, the Budget was relatively light on proposals affecting businesses....more

White & Case LLP

Belgian draft law ratifying the MLI: A new paradigm in international tax law

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On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more

Hogan Lovells

The outcomes of the Davis tax committee

Hogan Lovells on

In March the Davis tax committee released its closing report on the work completed over almost five years and at a cost of approximately ZAR12.4 million....more

Akin Gump Strauss Hauer & Feld LLP

UK ratifies the OECD’s Multilateral Instrument – Practical Impact and Timing of Implementation

On 23 May 2018, the United Kingdom ratified the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, otherwise known as the ‘Multilateral Instrument’ (“MLI”). The...more

Jones Day

Investor-Friendly Tax Treaty Set for Mexico and Spain

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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

Orrick, Herrington & Sutcliffe LLP

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

Jones Day

Japan Legal Update - Volume 27 | July 2017

Jones Day on

On June 7, 2017, Japan signed the "Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting" ("MLI"). The MLI is a part of the OECD/G20 base erosion and profit-shifting...more

Alston & Bird

Impact of the Multilateral Instrument on U.S. Taxpayers

Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more

Proskauer - Tax Talks

BEPS Update: OECD Multilateral Instrument Signed

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On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

Proskauer - Tax Talks

BEPS: Update on Action 6 on Treaty Benefits

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In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

Proskauer - Tax Talks

BEPS: OECD Releases Multilateral Tax Treaty Convention

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The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

Dechert LLP

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

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India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

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