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
7/9/2025
/ Corporate Taxes ,
Cross-Border ,
HM Treasury ,
HMRC ,
Intellectual Property Protection ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Planning ,
Taxation ,
Transfer Pricing ,
UK
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
On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a...more
Following the OECD’s long-awaited guidance that was issued in December 2022, Pillar One’s Amount B has begun receiving renewed attention. Jessie Coleman, transfer pricing principal with KPMG, joined the “GILTI Conscience”...more
With more and more countries signing on to Pillar Two, “GILTI Conscience” hosts Nate Carden and David Farhat are joined by Vikram Chand, associate professor of law at the University of Lausanne, to discuss what this means for...more
5/24/2023
/ Business Taxes ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
International Tax Issues ,
New Legislation ,
New Regulations ,
OECD ,
Tax Legislation ,
Tax Planning ,
Tax Policy
For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more
4/19/2023
/ Business Taxes ,
Corporate Taxes ,
International Tax Issues ,
International Trade ,
Mentor-Protege Program ,
Mentors ,
OECD ,
Tax Legislation ,
Tax Planning ,
Transfer Pricing ,
Young Lawyers
Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more
On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more
In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more
In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing...more
Introduction -
Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more