5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
The French tax authorities have issued new guidelines on the VAT treatment of company cars provided to employees. When a vehicle is provided for a defined consideration, it is considered a taxable service. This includes...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother...more
Introduction - With its corporate laws based upon those of the UK, Malta has incorporated laws and principles into its own legislation, providing comfort and security to the commercial and business community. The most...more
La Cour administrative d'appel de Paris rappelle à l'administration fiscale son obligation de motivation de la réponse aux observations du contribuable sous peine d'entacher la procédure d'irrégularité (CAA Paris, 13 février...more
La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more
Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more
Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more
The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more
1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership -...more
On December 20, 2024, the Luxembourg parliament adopted without material changes the tax relief package bill that we covered in a previous publication. Amongst others, this law introduces, as of fiscal year 2025, the...more
Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more
Introduction - Cyprus is an EU member state and a common law jurisdiction with a legal system similar to that of the UK. It is located at the eastern end of Europe linking 3 continents, Europe, Africa and Asia and it has...more
The global tax landscape is experiencing a profound transformation as the OECD/G20’s Pillar Two rules are adopted. Among these, the Undertaxed Profits Rule (UTPR) has emerged as a pivotal mechanism designed to ensure that...more
We recently hosted a webinar on Pillar Two and its practical impact on joint ventures (JVs). Our key takeaways are set out below. Introduction to Pillar Two - Pillar Two, also known as the global minimum tax, is an...more
The concept of a pan-European company has garnered renewed attention, with an online petition launched in mid-October amassing over 10,000 signatures in two weeks. The petition advocates for the creation of EU Inc., a new...more
Welcome to the September 2024 edition of our UK Tax Round Up. This month has seen decisions on UK tax residence, VAT group eligibility and the Supreme Court’s ruling in the long running case involving the employment status of...more
The November U.S. Presidential electoral campaign is in full swing. Since President Joe Biden ended his reelection bid and Vice President Kamala Harris secured the Democratic Party nomination, polls now show a tight race...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother company,...more
1. Specific Financial Asset Types - 1.1 Common Financial Assets - A wide range of asset classes have been securitised by Irish special purpose entities (SPEs): residential mortgages; commercial mortgages; auto loans;...more
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
The Budget Law extends the applicability of the Italian participation exemption regime (Italian PEX) to companies and trade entities which are resident in an EU or EEA member State (that allows an adequate exchange of...more
1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership ...more
Introduction - Cyprus is an EU member state and a common law jurisdiction with a legal system similar to that of the UK. It is located at the eastern end of Europe linking 3 continents, Europe, Africa and Asia and it has a...more