Tax Reform, Corporate Taxes, Transfer Pricing

UK Consults on Draft Legislation on Transfer Pricing, Permanent Establishments and Diverted Profits Tax

Skadden, Arps, Slate, Meagher & Flom LLP on 5/20/2025

On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more

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

Freeman Law on 9/29/2022

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

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

Skadden, Arps, Slate, Meagher & Flom LLP on 1/25/2022

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

UK Tax Round Up - September 2017

Proskauer Rose LLP on 9/22/2017

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on 10/5/2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

India at the Crossroads

McDermott Will & Emery on 3/26/2013

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more