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McDermott Will & Schulte

France’s Digital Services Tax Faces Constitutional Crossroads

In a significant development for multinational companies operating in the digital space, France’s Supreme Administrative Court (Conseil d’État) has referred the country’s Digital Services Tax (DST) regime to the...more

Proskauer Rose LLP

UK Tax Round Up - July 2025

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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Proskauer - Tax Talks

President Trump Signs One Big Beautiful Bill Act into Law

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more

Mayer Brown

Asia Tax Bulletin - Summer 2025

Mayer Brown on

We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong’s and Japan’s tax legislation to implement the Minimum Global Tax (also referred...more

Alston & Bird

Breaking Down the Tax Provisions of the One Big Beautiful Bill Act

Alston & Bird on

The One Big Beautiful Bill Act is a massive bill that overhauls much of the U.S. tax system. Our Federal & International Tax and State & Local Tax teams cover the Act’s key tax provisions for individuals and businesses....more

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

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

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The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Finance Committee Proposes Key Departures From House Provisions for the One Big Beautiful Bill Act - June Insights

On June 16, 2025, the Senate Finance Committee released its version of the tax-related proposals (Senate Bill) for inclusion in the One Big Beautiful Bill Act (OBBBA). In line with the bill the House passed on May 22, 2025...more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Finance Committee Proposes Key Departures From House Provisions for the One Big Beautiful Bill Act

Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

DLA Piper

New VAT Guidelines on Company Vehicles for Employees

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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

White & Case LLP

Important Tax Update: Luxembourg Court Decision on Interest Free Loans and Debt to Equity Ratio – A Global Impact

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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

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

Whiteford on

On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

White & Case LLP

Mexican Tax Authority (SAT) Substantially Increases Transfer Pricing Tax Collections

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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

McDermott Will & Schulte

The Proposed US Tax Regime for Non-US Investors and Companies

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Skadden, Arps, Slate, Meagher & Flom LLP

The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

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Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

DLA Piper

Netherlands - VAT: Dutch Attorney General (AG) Issues Conclusion on Impact of Receiving VAT Exempt Interest Income on VAT Recovery...

DLA Piper on

Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

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On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

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In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

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Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

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