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Corporate Taxes Organization for Economic Co-operation and Development

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

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

Kyiv Tax Newsletter - November 2017 #2

by Dentons on

Increased withholding tax rates in the instances of application of the Convention between the Government of Ukraine and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double...more

UK Tax Round Up - October 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Global In-House Centers in India, v2.0

GICs in India are evolving from cost-saving platforms into Innovation Centers for emerging digital technologies that can provide a competitive advantage. Recent years have seen a resurgence of interest in GICs in India...more

UK Tax Round Up - September 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

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

UK Tax Round Up - August 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

Luxembourg announces new IP tax regime

by DLA Piper on

Luxembourg has announced a new regime that offers a special tax incentive for certain income from intellectual property rights. The bill containing the new IP regime, which is expected to come into effect as of the 2018 tax...more

Branch Report: The Future of Transfer Pricing

by DLA Piper on

The prepared Branch Report is dedicated to Subject 2 of the Congress 'The Future of Transfer Pricing'. It outlines Ukrainian transfer pricing regulations and practices as of the end of 2016, as well as analyses impact of the...more

UK Tax Round Up - July 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...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

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...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

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

BEPS – are you affected?

by Ropes & Gray LLP on

Over 100 countries and jurisdictions are collaborating through the OECD to implement measures to tackle base erosion and profit shifting (BEPS). The OECD have set out 15 actions points that aim to equip governments with the...more

Is Your Customs Compliance BEPS Ready?

by 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

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

BEPS: Update on Action 6 on Treaty Benefits

by Proskauer - Tax Talks on

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

Base erosion and profit shifting - new regulations

by 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

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

by Dechert LLP on

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

German tax law changes and their impact on multinationals

by DLA Piper on

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

Tax break for infrastructure projects

by DLA Piper on

To implement the G20/OECD base erosion and profit shifting project, the 2016 Budget announced measures limiting tax deductions that companies can claim from their interest expenses (read DLA Piper's earlier client alert on...more

Country by Country: Spain

by DLA Piper on

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

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