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Tax Planning Transfer Pricing Corporate Taxes

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

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

Proskauer Rose LLP

UK Tax Round Up - February 2025

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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Mayer Brown

Prix de transfert : la détermination du taux d'intérêt de référence concernant les avances intragroupe

Mayer Brown on

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime de la charge de la preuve en matière de prix de transfert en présence d'avances consenties sans...more

Mayer Brown

Mise à jour de la doctrine administrative relative aux prix de transfert

Mayer Brown on

À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing

For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

McDermott Will & Schulte

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

Miller Nash LLP on

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Akerman LLP - SALT Insights

Louisiana Launches Unique State Transfer Pricing Initiative

Joining Indiana and North Carolina, Louisiana last week became the third state to offer an alternative to the burdensome and expensive process of enduring a state transfer pricing audit....more

McDermott Will & Schulte

[Webinar] Novità Fiscali Fine 2020 - January 21st, 3:00 pm - 5:00 pm CET

Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more

McDermott Will & Schulte

[Webinar] Tax News At The End Of 2020 - January 21st, 3:00 pm - 5:00 pm CET

Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to businesses....more

Proskauer Rose LLP

UK Tax Round Up - December 2020

Proskauer Rose LLP on

COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

Proskauer - Tax Talks on

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

Proskauer Rose LLP on

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

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Womble Bond Dickinson on

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

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

Bennett Jones LLP

International Tax & Transfer Pricing Strategies in the Crosshairs

Bennett Jones LLP on

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

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