News & Analysis as of

Corporate Taxes Multinationals

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Deemed Dividends Under Proposed Tax Reform

by Miles & Stockbridge P.C. on

2017 tax reform efforts may alleviate adverse deemed dividend tax treatment of foreign subsidiary support for the obligations of U.S. parent companies. Present support is limited to the pledge of 66 ?rds of the stock in...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

by Latham & Watkins LLP on

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

Tax Residency - Place of Effective Management in South Africa

by Dentons on

The concept of residency is a crucial determinant in establishing a person’s tax obligations in South Africa. Generally, a resident is liable to pay tax on taxable income derived from South Africa and globally, while...more

Australian Tax Update

by DLA Piper on

Introduction and overview The Australian Treasurer, The Hon Scott Morrison MP, on Friday 24 November 2017, released exposure draft legislation to prevent entities that are liable to Australian income tax from avoiding...more

Worldwide Territoriality: International Tax Proposals Broaden the Base

On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more

Technology companies and transfer pricing

by 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

China tax incentives for advanced technology service enterprises rolled out to the entire nation: key features

by DLA Piper on

The China tax incentives for Advanced Technology Service Enterprises (ATSE) were first introduced in the Suzhou Industrial Park in 2006, then applied to 21 pilot cities in 2014, and subsequently expanded to another 11 cities...more

EU & Competition Law Update – November 2017

by Bryan Cave on

EU opens investigation into UK tax scheme for multinationals - The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal...more

Tax Reform Proposals Would Have Significant Consequences for Foreign Multinationals Doing Business Through Affiliates in the...

by White & Case LLP on

Both the House and the Senate tax reform proposals were designed to move the United States toward a territorial tax regime and both proposals contain base erosion protections intended to prevent otherwise taxable income from...more

South African Revenue Service scrutinizes taxable presence of foreign service providers in South Africa

by DLA Piper on

Foreign service providers are starting to receive requests for information from the South African Revenue Service (SARS) relating to activities that have been conducted in South Africa. During 2016, SARS extended the...more

The Tax Cuts and Jobs Act

by Proskauer - Tax Talks on

Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more

European Commission Opens State Aid Investigation Into Finance Company Exemption From UK CFC Rules

On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

by Jones Day on

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

The proposed US tax reform: repatriation alternatives for multinationals operating in Latin America

by DLA Piper on

The proposed US tax reform may incentivize multinational companies that have made investments in Latin America to pursue repatriation alternatives such as dividend distributions and capital reduction. However, the...more

Trump Administration and Congressional Leaders Release Tax Reform Framework

by Shearman & Sterling LLP on

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

Republicans release new tax reform framework

by Dentons on

On September 27, 2017, the Trump administration and Republican leaders in Congress released their "Unified Framework for Fixing our Broken Tax Code." This nine-page document is the result of months of meetings on tax reform...more

2018 Dutch Tax Plan - changes to Dutch dividend withholding tax

by DLA Piper on

The Dutch Ministry of Finance has published the 2018 Budget and, in connection with it, the 2018 Tax Plan. The 2018 Tax Plan contains a number of already anticipated changes to Dutch tax legislation effective as of January 1,...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

by Dorsey & Whitney LLP on

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

The Impact of Tax Reform on Private Equity

If the past 12 months have taught us anything, it’s that the future is hard to predict. One need only look at the ascendancy of Brexit, President Donald Trump, or even the New England Patriots in the second half of the Super...more

113 Results
|
View per page
Page: of 5
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.