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
Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more
The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more
Guernsey has passed legislation to implement the OECD's global minimum tax rate of 15%, known as "Pillar 2", which will apply for fiscal years commencing on or after 1 January 2025....more
Guernsey and Jersey have today issued a joint statement with the Isle of Man on their intentions to implement the OECD global initiative to set a minimum effective tax rate for the world’s largest multinational enterprises,...more
The Beneficial Ownership Secure Search System (Amendment) (No.2) Act, 2021 (“Amendment Act”) was gazetted in the BVI on 31 December 2021 and came into force on 1 January 2022. The Amendment Act amends the BVI’s Beneficial...more
Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...more
We have recently received many queries from Israeli investors about the increased demands for KYC (know your customer) and AML (anti-money laundering) documents from Cayman Islands investment funds. Therefore, we thought it...more
The introduction of economic substance requirements in offshore jurisdictions has sharpened the impetus for investment fund managers to establish a physical office where their funds are incorporated. Here are six good reasons...more
Hong Kong has taken a further step towards establishing itself as a leading fund formation jurisdiction with the passing of the Limited Partnership Fund Ordinance which is expected to become effective on 31 August 2020, to...more
The EU’s Economic and Financial Affairs Council (ECOFIN) maintains a list of non-cooperative jurisdictions for tax purposes; the purpose of which is to contribute to ongoing efforts to promote tax good governance worldwide....more
The Financial Stability Board has published a report on crypto-assets outlining the actions being undertaken by various international organizations in response to the challenges posed by crypto-assets and the FSB's own...more
Energy Companies to Appeal Loss of Forest Service Permit for Atlantic Coast Pipeline - "The builders of the $7 billion Atlantic Coast Pipeline say they will appeal a federal court ruling that invalidated a permit allowing...more
• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
Increasingly complex fund structures and documentation mean that analysing how potential portfolio acquisitions interact with the fund at the top of any deal structure is more important now than ever. Investor Excuse...more
International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
The Second Circuit took center stage this week, handing down a decision which reversed the insider trading convictions of two remote tippees. The decision circumscribes tippee liability by defining the elements of a claim and...more