GILTI Conscience Podcast | Adapting to Tariff Volatility in International Business
AGG Talks: Cross-Border Business Podcast - Episode 31: The Ripple Effects of Tariffs and Transfer Pricing on Global Business
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The 2025 federal budget includes draft legislation that would implement a significant rewrite of Canada’s transfer pricing provisions, largely aligned with proposals released in a 2023 Department of Finance Consultation...more
In SC Arcomet Towercranes SRL (Case C-726/23) (4 September), the CJEU found that transfer pricing adjustments can fall within the scope of VAT if there is a direct link between the services provided and the compensation...more
Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual...more
On November 4, 2025 (Budget Day), the Government of Canada released its 2025 federal budget (Budget 2025), which proposes to introduce a number of noteworthy tax measures, including...more
Earlier Tuesday, the Honourable François-Philippe Champagne, Minister of Finance and National Revenue, delivered the Liberal Party’s first federal budget under Prime Minister Mark Carney (Budget 2025). Budget 2025 does not...more
Tariffs are reshaping global supply chains, transfer pricing and IP valuations — creating new challenges for businesses. This episode of “GILTI Conscience” features guests Brooks Allen and Jonathan Welbel, Skadden national...more
Circular 7 remains a cornerstone of China’s approach to taxing indirect transfers and continues to influence the structuring of cross-border M&A transactions. While Circular 7’s formal provisions have not changed, the way it...more
As the global economy enters a new phase of regulatory transformation, tax compliance has become a defining challenge for businesses across Europe. In 2025, heightened scrutiny from tax authorities, the expansion of...more
It is axiomatic that a transaction between related businesses – i.e., businesses that are owned or controlled directly or indirectly by the same interests (a “controlled group”) – will generally be subject to heightened...more
Many companies depend on the acquisition of IP-protected technologies through either internal R&D or M&A transactions. In either case, the company must integrate the relevant IP so that it can use the technologies to sell new...more
En matière de TVA, la Cour de justice de l’Union européenne juge que la rémunération de services intragroupe, versée par une filiale à sa société mère en application d’un contrat de prestations détaillées, et calculée selon...more
This glossary aims at explaining frequently used terms in taxation in a simple manner. ...more
In this episode, Mike Burke, AGG Corporate partner and chair of the International Practice, welcomes back Sean King, president and founder of Align Global Consulting and the podcast’s very first guest. Mike and Sean discuss...more
Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more
The Trump administration’s fluctuating tariffs pose major compliance risks for businesses operating in the U.S. Dive into the challenges they pose to businesses that rely on imported goods and services as Marina Gentile...more
“GILTI Conscience” takes on the world of high-fashion, as Skadden tax partner and host David Farhat is joined by associate Stefane Victor and Giuseppe Abatista, vice president at Banca Popolare di Puglia e Basilicata, as they...more
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more
Join us for an insightful episode of “GILTI Conscience” as David Farhat, Eman Cuyler and Stefane Victor — together with our special host Skadden tax partner Loren Ponds and guest Fernando Colucci, partner at Machado Meyer in...more
On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more
On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more
Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more
Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more