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Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

Morgan Lewis on

Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion

“GILTI Conscience” takes on the world of high-fashion, as Skadden tax partner and host David Farhat is joined by associate Stefane Victor and Giuseppe Abatista, vice president at Banca Popolare di Puglia e Basilicata, as they...more

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

DLA Piper

El Servicio de Impuestos Internos Publica su Catálogo de Esquemas Tributarios 2025

DLA Piper on

Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

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Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Cadwalader, Wickersham & Taft LLP

EU’s Ambition Beyond BEPS 2.0

On May 18, 2021, the European Commission (the Commission) of the European Union (the EU) published a communication on “Business Taxation for the 21st Century” (the Communication), setting out a long-term vision to provide a...more

Proskauer Rose LLP

UK Tax Round Up - March 2021

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Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

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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

Proskauer Rose LLP

UK Tax Round Up - January 2021

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UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

Proskauer Rose LLP

UK Tax Round Up - November 2020

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

Womble Bond Dickinson

Torturous Treatment of Transatlantic Trusts

Womble Bond Dickinson on

I say Settlor… The popularity of lifetime trust giving in the UK has been on a downward trend since April 2006 when the Labour government introduced reforms specifically aimed at stopping trusts “being used to shelter wealth...more

Hogan Lovells

Tech Tax – Looking Forward to 2020

Hogan Lovells on

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

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