News & Analysis as of

Cross-Border Organization for Economic Co-operation and Development International Tax Issues

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Eversheds Sutherland (US) LLP

Impermanent establishments, COVID-19, and the OECD’s response

At the request of concerned countries, the Organisation for Economic Co-operation and Development (OECD) Secretariat has weighed in on tax considerations that are important both to businesses and to their employees as they...more

Jones Day

France and Luxembourg Sign New Tax Treaty

Jones Day on

The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...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

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