GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
AI Around the Globe: What to Know in 2024
GILTI Conscience Podcast | Amount B Back in the Spotlight
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 New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
FCPA Compliance Report-Episode 333, Professor Samuel Buell
FCPA Compliance Report-Episode 329, James Koukios
Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to...more
There have been several recent developments in trade disputes involving the Trump Administration and the European Union (EU), including an increase by the U.S. Trade Representative in tariffs on new Airbus aircraft and...more
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
On December 2, 2019, the U.S. Trade Representative (USTR) announced that in response to a digital services tax law passed in France, it would be retaliating with stringent tariffs on luxury products coming from France. The...more
On December 2, 2019, the Office of the US Trade Representative (USTR) announced its determination that France's Digital Services Tax (DST) is "unreasonable or discriminatory and burdens or restricts U.S. commerce" and is...more
This Week: USTR holds hearing on French digital services tax; EU to consider new regulation governing online platforms; Sanders, Warren take on facial recognition technology in new criminal justice reform proposals....more
On July 11, 2019, the French Parliament adopted the bill creating a tax on digital services, applicable as from January 1, 2019. Failed International Attempts - The desire to adjust tax policy in the digital age is not...more
The Office of the U.S. Trade Representative (“USTR”) announced on July 10 the initiation of an investigation under Section 301 of the Trade Act of 1974 into France’s digital services tax (“DST”). The French Senate...more
The Gauvain Report to "Restore the sovereignty of France and Europe and protect our companies from laws and measures with extraterritorial scope" was submitted to the French Prime Minister on 26 June 2019. As its name...more
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
Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more
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
Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more
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
In April 2017, the European Commission ("Commission") published a tender offer seeking an assessment of the EU market for loan syndication and possible implications under EU competition rules. The successful candidate will...more
The search for yield continues...Techniques honed in the more mature US leveraged finance market continue to be imported into European deals and then across to the APAC markets, requiring skillful reworking in some cases to...more
The French Finance Act for 2016 and Amending Finance Act for 2015 were enacted on December 30, 2015 (the “Acts”). Under the new legislation, the neutralization of the 5% add-backs on dividends within tax-consolidated groups...more
Welcome to the April 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month in anticorruption developments, Canadian transportation giant faces scrutiny for alleged bribery in South...more
On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this...more
International pressure is mounting for France to boost their anti-bribery and corruption efforts, but French organisations face the most serious risks—and have the greatest need for strong compliance programmes—today....more