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Corporate Taxes › HMRC › Multinationals

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Skadden, Arps, Slate, Meagher & Flom LLP on

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

A&O Shearman

UK moves closer to a Pillar Two reality

A&O Shearman on

The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more

Hogan Lovells

HMRC introduces Profits Diversion Compliance Facility

Hogan Lovells on

HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more

McDermott Will & Emery

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

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