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Ireland Organization for Economic Co-operation and Development

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

Morgan Lewis on

Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Walkers

Budget 2024 – Tax Highlights Ireland

Walkers on

10 October 2023 – Ireland's Budget 2024 was presented in the context of a positive economic performance for Ireland — full employment, budget surpluses, rising population and a falling national debt — against a backdrop of...more

Cadwalader, Wickersham & Taft LLP

Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply

The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more

White & Case LLP

Understanding Tax: EU tax challenges for cross border investing and financing

White & Case LLP on

This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more

Holland & Knight LLP

DIAN emite interpretación de Convenios para Evitar la Doble Tributación suscritos por Colombia

Holland & Knight LLP on

El 13 de diciembre de 2019 entró en vigor el Convenio para Evitar la Doble Tributación entre Colombia y el Reino Unido e Irlanda del Norte y su aplicación en materia de retenciones en la fuente será a partir del 1 de enero de...more

McDermott Will & Schulte

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Proskauer Rose LLP

UK Tax Round Up - October 2017

Proskauer Rose LLP on

UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Orrick, Herrington & Sutcliffe LLP

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for October 2016

Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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