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 Financial Stability Board (FSB) has announced the establishment of a forum on cross-border payments data, a key outcome from the FSB's recommendations for data frameworks related to cross-border payments published in...more
At the end of 2020, the United Kingdom (UK) and the European Union (EU) signed the EU-UK Trade and Cooperation Agreement (TCA), which both parties then ratified in 2021. As to antitrust cooperation, the agreement emphasized...more
This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more
A year in review for the ChatGPT (chatbot generative pre-trained transformer) — and a look ahead at the global response to AI & which governance “guardrails” are required. On November 30th, 2023, the world will celebrate...more
Stapled W&I policies and synthetic policies will likely be increasingly common features of E&I transactions, although their feasibility should be assessed case by case. Warranty and indemnity insurance (W&I) is a...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
White & Case Global Antitrust Merger StatPak (WAMS)—the first real-time clearinghouse for global merger notification data—has analyzed merger notifications in reporting jurisdictions around the first half of calendar year...more
The new securitisation framework will combine three sets of overlapping rules, in an effort to repeal and replace retained EU law in the UK. The missing piece of the puzzle to the UK’s new securitisation framework became...more
United States: The Administration and Congress are taking initial steps to produce legislation to regulate AI and using interim measures, such as the White House’s recently announced voluntary agreement with seven prominent...more
This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more
The Guidelines build on current social, environmental, and technological issues facing businesses following the last update in 2011. The Organisation for Economic Co-operation and Development (OECD) released updated...more
Legislators in the State of New York (NY), whose law governs many sovereign debt contracts, introduced three general categories of bills related to sovereign debt restructurings. The first is intended to provide support under...more
Welcome to the inaugural Private Markets Update, which highlights developments in the European private markets, covering the issues that matter to investors in alternative assets. Touching on themes as diverse as predictions...more
As the European Union (“EU”) continues to debate whether downstream responsibilities will fall within the contours of its hefty Corporate Sustainability Mandatory Due Diligence Directive (“CSMDD”), and the EU Council just...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...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 United States Trade Representative (“USTR”) Katherine Tai announced 25% additional tariffs on approximately $2 billion worth of imported goods from Austria, India, Italy, Spain, Turkey, and the United Kingdom (“UK”),...more
UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
In a surprise end-of-year gift to UK taxpayers and tax advisors, the UK will no longer be fully implementing the EU’s Mandatory Disclosure Regime (DAC 6) reporting requirements...more
Covid-19 is an unprecedented health and economic crisis, and it is still unclear how and when the aviation industry will begin to recover. Global government aid to the aviation sector has been inconsistent, with varied levels...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
UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more
UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more
• Public consultation follows release of OECD discussion draft on potential tax changes to address difficulties in taxation caused by the digital economy. • OECD hopes to produce “consensus document” with proposed...more