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Corporate Taxes BEPS Transfer Pricing

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

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: Canada

Freeman Law on

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

Jones Day

EU Court Overturns Commission Decision in Landmark Apple Tax Case

Jones Day on

The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...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

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Womble Bond Dickinson on

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

Hogan Lovells

Hong Kong enacts BEPS compliant transfer pricing legislation

Hogan Lovells on

On 13 July 2018, Hong Kong enacted detailed transfer pricing legislation through the gazettal of the Inland Revenue (Amendment) (No. 6) Ordinance 2018 ("the Amendment Ordinance")....more

Hogan Lovells

Technology companies and transfer pricing

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

Bennett Jones LLP

Is Your Customs Compliance BEPS Ready?

Bennett Jones LLP on

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

Hogan Lovells

Base erosion and profit shifting - new regulations

Hogan Lovells on

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

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

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