News & Analysis as of

Corporate Taxes Royalties

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

Holland & Knight LLP

Inexequibilidad de prohibición de deducción de regalías del impuesto sobre la renta en Colombia

Holland & Knight LLP on

La Sala Plena de la Corte Constitucional de Colombia el 16 de noviembre de 2023, profirió la Sentencia C-489 de 2023 por medio de la cual se resolvió declarar inexequible el parágrafo 1 del artículo 19 de la Ley 2277 de 2022...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Awatif Mohammad Shoqi Advocates & Legal...

What You Need To Know About Direct Taxation Of Businesses In The UAE

The UAE has not imposed corporate taxes on profits of most corporations or other businesses historically. That said, the Government of UAE will be introducing corporate tax to be levied on businesses, effective for financial...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Goodwin

Luxembourg: New Rule Disallowing Deduction On Payments To EU Non-cooperative Countries

Goodwin on

Luxembourg has introduced new legislation disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European...more

Vinson & Elkins LLP

UK Budget 2021: Tax Perspectives

Vinson & Elkins LLP on

On 3 March 2021, UK’s Chancellor Rishi Sunak announced the 2021 Budget, outlining the state of the economy and the government’s fiscal plans for the near to medium term. As expected, the chancellor’s speech focused on changes...more

White & Case LLP

German IP Withholding Tax

White & Case LLP on

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

Hogan Lovells

French legal and regulatory update - July/August 2019

Hogan Lovells on

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e - newsletter, which offers a legal and regulatory update covering France and Europe for April 2018. ...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2018 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Proskauer Rose LLP

UK Tax Round Up - December 2017

Proskauer Rose LLP on

Finance (No. 2) Bill 2017-19 - The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more

Eversheds Sutherland (US) LLP

Virginia Supreme Court Limits Corporate Income Tax Addback Exception

On August 31, 2017, the Virginia Supreme Court issued its opinion holding that only the portion of royalties that are actually taxed by another state falls within its “subject to tax” exception to Virginia’s addback statute...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

McDermott Will & Emery

Washington ALJ Upholds B&O Assessment on German Company’s Royalty Income

McDermott Will & Emery on

On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The...more

Akin Gump Strauss Hauer & Feld LLP

UK Budget 2016: Key Implications for Financial Services

On Wednesday March 16, 2016, George Osborne delivered his eighth budget as the U.K.’s Chancellor of the Exchequer, which included a number of announcements that will be relevant to the financial services industry....more

Morgan Lewis

UK Tax Measures—Spring 2016 Budget

Morgan Lewis on

The spring budget includes a number of announcements that relate to taxation, the most significant of which is a “roadmap” for UK corporate taxation through 2020....more

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

McDermott Will & Emery

Focus on Tax Controversy - Spring 2015

McDermott Will & Emery on

In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more

McNees Wallace & Nurick LLC

Focus on Pennsylvania Corporate Taxes

With the November 4th election of Democrat Tom Wolf as Pennsylvania’s next Governor, Pennsylvania corporate taxpayers face an interesting budget season in 2015. During the campaign, Wolf advocated for a severance or...more

Morrison & Foerster LLP

Indiana DOR Finds Economic Nexus, Disregards UPS

The Indiana Department of Revenue recently concluded that a company that earned royalty income from licensing trademarks and trade names to two of its Indiana affiliates, and had no physical presence in the state, nonetheless...more

McNees Wallace & Nurick LLC

Home Stretch to a PA Budget

As the Pennsylvania General Assembly heads down the home stretch to the June 30th deadline for passage of a budget for 2013-14, all indications suggest that the budget package will include significant substantive and...more

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