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Transfer Pricing BEPS

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

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International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Freeman Law

International Tax Treaty: Canada

Freeman Law on

Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...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

Hogan Lovells

Transfer pricing in the new global economy

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Driven by ever-advancing technologies, today’s multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, especially...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...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

Hogan Lovells

Hong Kong enacts BEPS compliant transfer pricing legislation

Hogan Lovells on

On 13 July 2018, Hong Kong enacted detailed transfer pricing legislation through the gazettal of the Inland Revenue (Amendment) (No. 6) Ordinance 2018 ("the Amendment Ordinance")....more

Hogan Lovells

Technology companies and transfer pricing

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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

Proskauer - Tax Talks

BEPS Update: OECD Multilateral Instrument Signed

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On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - April 2017

McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

Alston & Bird

IRS Issues Draft Form and Instructions for Country-by-Country Reports

Alston & Bird on

Country-by-Country (CbC) reporting is now generally required for the ultimate parent of a U.S. multinational enterprise (MNE) for tax years that begin on or after June 30, 2016. On January 11, 2017, the IRS released a draft...more

Bennett Jones LLP

Is Your Customs Compliance BEPS Ready?

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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

Hogan Lovells

Base erosion and profit shifting - new regulations

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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

Proskauer - Tax Talks

New Public Country-by-Country Reporting of Financial Information Proposed by European Commission

Proskauer - Tax Talks on

Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more

McGuireWoods LLP

Tax Policy Update

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After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

McGuireWoods LLP

OECD Releases Final BEPS Recommendations – Now What?

McGuireWoods LLP on

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

McDermott Will & Emery

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

McDermott Will & Emery

2014 Transfer Pricing Resolutions

Happy New Year! It’s time to make your 2014 transfer pricing resolutions: read a good book, learn a new language and, of course, exercise, exercise, exercise. 2013 was a very active year from a transfer pricing...more

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