Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
On 14 February 2019, the General Court of the European Union (GCEU) annulled the decision of the European Commission (Commission) on the Belgian excess profit exemption system (SA.37667) in its entirety on the ground that the...more
While much attention has been paid to the maximum level of administrative fines under the General Data Protection Regulation (GDPR) — up to 4 percent of total worldwide annual turnover — the regulation also provides for...more
The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...more
The UK Government has set out a bold vision for a post-Brexit world: The UK as a global pivot; a strategic partnership with the EU; an enduring and perhaps an even more “special” relationship with the U.S. ...more