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Goodwin

Proposed Amendments to Pillar Two Law in Luxembourg

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On 12 June 2024, Luxembourg published a bill of law amending the law of 22 December 2023 (the Pillar Two Law[1]) implementing EU directive no. 2022/2523, largely known as the “EU Minimum Tax Directive” or “Pillar Two...more

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

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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

Goodwin

Pillar Two Implementation in Luxembourg

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On 4 August 2023, Luxembourg published a bill of law (the “Bill”) to transpose the EU directive no. 2022/2523 largely known as the “EU Minimum Tax Directive” or “Pillar Two Directive”, ensuring a minimum global Effective Tax...more

Cadwalader, Wickersham & Taft LLP

Regulation: EU Reaches Agreement on Carbon Border Tax

Environmental regulators and ministers from across the EU member states provisionally approved the introduction of the world’s first major carbon border tax, the Carbon Border Adjustment Mechanism (CBAM), which will require...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

McDermott Will & Emery

An Overview of OECD Pillar 2

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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

White & Case LLP

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

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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

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

A&O Shearman

The global minimum tax rate: Are we nearly there yet?

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On 20 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation. ...more

Cohen & Gresser LLP

[Webinar] Preparing an International Legislative Strategy - September 28th, 12:00 pm EST

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Earlier this summer, the Group of Seven (G7) held their annual summit to coordinate global policy and devise a plan to help the world build back better from COVID-19. The G7 discussed several priorities and initiatives,...more

Latham & Watkins LLP

G7 Tax Agreement Marks Significant Step Toward Global Tax Reform

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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

Sheppard Mullin Richter & Hampton LLP

USTR Suspends Tariffs on Certain French Luxury Goods: A Potential Shift in Trade Talks

Key Takeaways: • Threatened 25% tariffs on French luxury goods are suspended. • USTR is still looking at tariffs in retaliation for taxes on U.S. global tech companies. • Biden’s new USTR will face immense pressure to...more

Orrick, Herrington & Sutcliffe LLP

Legge di Bilancio 2021: ulteriore proroga per la rideterminazione dei valori di terreni e partecipazioni

Con la legge di Bilancio 2021, il legislatore ha prorogato anche per il 2021 la possibilità di rideterminare il valore di acquisto dei terreni e delle partecipazioni non negoziate nei mercati regolamentati. Si tratta della...more

Hogan Lovells

Italian Government repeals money transfer tax

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The Italian Government repealed the tax, introduced in 2018, on money remittances outside EU executed through payment institutions....more

Proskauer Rose LLP

UK Tax Round Up - November 2020

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UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

Hogan Lovells

The new Digital Service Tax has entered into force in Italy

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With the approval of Law 27 December 2019, no. 160 (the Budget Law), the Italian digital services tax (the DST), initially provided by Law 30 December 2018, no. 145, has finally come into force, being effective as of 1...more

Orrick, Herrington & Sutcliffe LLP

Frances Draft 2019 Finance Bill Reforms Interest Deductibility Limitation Rules

The French government presented the draft Finance Bill for 2019 on September 24, 2018. This draft is currently being discussed by the Parliament and is subject to potential changes....more

Proskauer Rose LLP

UK Tax Round Up - March 2018

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Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Interagency Statement on Accounting and Reporting Implications of the New Tax Law - On January 18, 2018, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal...more

Cadwalader, Wickersham & Taft LLP

Autumn Budget 2017 Predictions

The Chancellor of the Exchequer's first Autumn Budget under the new budget timetable, which sees the Autumn Statement replaced with an Autumn Budget (and the Spring Budget replaced with a Spring Statement), will be announced...more

Hogan Lovells

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

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Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Hogan Lovells

French Legal and Regulatory Update - February 2017

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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 February 2017. Commercial Law -...more

Hogan Lovells

State Aid: What we now know

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This week, the UK Prime Minister, Theresa May, set out the UK Government's long-awaited position on what the UK out of the EU should look like. The announcement of what is generally thought of as a "hard Brexit" negotiating...more

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