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A&O Shearman

What does Pillar Two mean for structured finance?

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Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more

BCLP

Impact of Pillar Two on Tax Risk Apportionment for a Corporate Sale

BCLP on

How do you draft a tax covenant for a corporate sale when the Seller Group is within the scope of a Pillar Two charge? This is an issue that will become increasingly relevant as we approach the Pillar Two start date at the...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

Proskauer Rose LLP on

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

McDermott Will & Emery

International Legal Highlights | June 2022

EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE - On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more

Cadwalader, Wickersham & Taft LLP

EU’s Proposal on Implementing Pillar Two

The European Commission has published its proposal for a Directive to implement the OECD Pillar Two Global Anti-Base Erosion rules (the “OECD GloBE Model Rules”)....more

McDermott Will & Emery

An Overview of OECD Pillar 2

McDermott Will & Emery on

The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more

McDermott Will & Emery

OECD Pillar 2 Q&A

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WHAT IS THE AIM OF PILLAR 2 RULES? The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, February 8, 2022

Legislative Lowdown - Build Back Better Reboot. Rep. Richard Neal (D-MA), the House Ways and Means Committee chair, and Sen. Ron Wyden (D-OR), chair of Senate Finance Committee, are cautiously optimistic negotiations over...more

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

White & Case LLP

ATAD III: Is the tide turning on shell companies?

White & Case LLP on

The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

Latham & Watkins LLP

G7 Tax Agreement Marks Significant Step Toward Global Tax Reform

Latham & Watkins LLP on

The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Key Points: ..Under Pillar One, the largest and most...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

Proskauer Rose LLP on

UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

Skadden, Arps, Slate, Meagher & Flom LLP

Plus Ça Change ... Reframing the Tax Influences of the European Union

Takeaways - While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK. - That is actually a good thing in one respect: UK...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

BCLP

Importance of conformity to international tax standards – Cayman Islands added to the EU blacklist of non-cooperative...

BCLP on

The EU’s Economic and Financial Affairs Council (ECOFIN) maintains a list of non-cooperative jurisdictions for tax purposes; the purpose of which is to contribute to ongoing efforts to promote tax good governance worldwide....more

McDermott Will & Emery

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

McDermott Will & Emery on

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

Proskauer Rose LLP

UK Tax Round Up - November 2019

Proskauer Rose LLP on

UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

Proskauer Rose LLP on

UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Eversheds Sutherland (US) LLP

Taxing the digital economy - The ABCs of the secretariat proposal for a “unified approach under pillar one”

On 9 October 2019, the Organisation for Economic Co-Operation and Development (OECD) published its latest public consultation paper in relation to its proposals to address the challenges of taxing the digital economy,...more

Bracewell LLP

New UAE Economic Substance Regulations Issued

Bracewell LLP on

On 30 April 2019, the UAE Cabinet issued the Cabinet of Ministers Resolution No. 31 of 2019 concerning Economic Substance Regulations in the UAE (“Regulations”). ...more

Akin Gump Strauss Hauer & Feld LLP

OECD Holding Public Consultation on the Tax Challenges of Digitalization

• Public consultation follows release of OECD discussion draft on potential tax changes to address difficulties in taxation caused by the digital economy. • OECD hopes to produce “consensus document” with proposed...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...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

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more

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