Taxing Intelligence: AI's Role in Modern Tax Administration
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
As artificial intelligence has taken center stage across industries, does it also have a place in tax administration? Our latest episode of “GILTI Conscience” explores potential applications of AI in the world of tax,...more
As part of its fiscal 2026 budget legislation (H.B. 352), Maryland enacted a significant change to its elective pass-through entity tax (PTET) regime. Effective for tax years beginning after December 31, 2025, the PTET base...more
The Israel Tax Authority (ITA) recently published updated guidelines, regarding tax aspects applying to investments in companies through SAFEs. Such guidelines were published following the previous guidelines published by the...more
El artículo 8 del Decreto 0175 de 14 de febrero de 2025 modificó el parágrafo 2 del artículo 519 del Estatuto Tributario Nacional de Colombia, reviviendo desde el 22 de febrero de 2025 hasta el 31 de diciembre de 2025 el...more
Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...more
The Israel Tax Authority (ITA) recently published an addendum to the 1987 circular with the goal of minimizing disputes with sellers of residential apartments. The addendum contains procedures addressing instances when...more
The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more
The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more
A district court ruling handed down this past September addresses the legitimacy of distributing dividends prior to a sale of shares in order to reduce the tax liability deriving from the transaction. The court found that, in...more
The uptrend in the number of public shell acquisitions has prompted the Israel Tax Authority to be even more meticulous in its examination of such transactions. The Jerusalem District Court recently ruled that when a buyer...more
The Spanish Tax Authorities ("STA") have issued the first ruling analysing the existence of a permanent establishment ("PE") in Spain due to an employee who worked from home during and after the COVID-19 lockdown. In this...more
French trust legislation has been in effect for 10 years, during which time some early uncertainties about its application have been resolved. The connections with France that trigger application of the legislation have been...more
Italian tax authorities address for the first time the VAT regime applicable to the assignment of NPLs. On the very last day of 2021 the Italian Revenue Agency issued a remarkable ruling (no. 79/E) on the VAT regime...more
The Israeli High Court of Justice ruled recently that section 46 of the Income Tax Ordinance does not authorize the Knesset Finance Committee to exercise broad discretion in recognizing NPOs and in fact the Committee’s...more
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more
Takeaways - While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK. - That is actually a good thing in one respect: UK...more
Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more
This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states. This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will...more
Draft bill published on 19 November 2020 offers hope that an unnecessary tax discussion may be brought to an end A German tax issue has been causing great uncertainty among international corporates since spring 2020: Are...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more
UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more
In our latest interactive webinar we will discuss DAC6 – the EU Directive on reportable cross-border tax arrangements – and its impact on business. The importance of DAC6 cannot be overstated. As an intermediary,...more
DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more
What is DAC6? ..DAC6 is a new regime under which intermediaries and/or taxpayers must report to an EU tax authority information about cross-border arrangements with a view to the information being exchanged with other tax...more