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
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
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
Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more
The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more
On Friday October 8, 2021, the Organization for Economic Cooperation and Development (OECD) announced that 136 Nations, including the United States and the rest of the G20, have signed on to the OECD/G20 Inclusive Framework...more
The Organisation for Economic Co-operation and Development (the “OECD”) recently announced that a landmark deal has been reached by 136 countries in an attempt to ensure that Multinational Enterprises (“MNEs”) are subject to...more
The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more
Tras la culminación del proyecto Erosión de la Base Desplazamiento de Beneficios (Base Erosion Profit Shifting o BEPS) en 2017, proyecto creado para combatir la erosión de la base gravable y estrategias para la transferencia...more
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Key Points: ..Under Pillar One, the largest and most...more
The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more
It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more
What is it about? OECD proposals to tax the digital economy which will significantly impact all large tech companies that are consumer oriented. What will the impact be? Businesses will pay more tax. Impact on cash-flow,...more
The Organization for Economic Cooperation and Development (OECD) released a draft proposal today detailing how countries should approach the taxation of multinational companies in an increasingly digitalized global economy....more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
The Commonwealth Senate Economics Committee (a standing committee composed by members of the upper house of Parliament) handed down its long-awaited final report on corporate tax avoidance in Australia. The final report is...more
The Base Erosion and Profit Shifting (BEPS) Project of the OECD was launched with the publication of the OECD BEPS Action Plan in 2013. The BEPS Project comprised various "Actions" aiming to fight tax avoidance strategies...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
As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more
International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more