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
1/28/2020
/ BEPS ,
Corporate Taxes ,
Cross-Border Transactions ,
Due Diligence ,
EBITDA ,
Financing ,
International Tax Issues ,
Multinationals ,
Risk Assessment ,
Risk Management ,
Tax Planning ,
Tax Treaty ,
Transfer Pricing
On March 21, 2018, the European Commission released a draft legislative package for “fair taxation of the digital economy,” which would establish new tax rules for digital business activities within the European Union. This...more
3/27/2018
/ Business Profits ,
Digital Single Market ,
Digital Taxes ,
Double Taxation ,
Economic Presence Nexus ,
EU ,
EU Single Market ,
European Commission ,
Gig Economy ,
Member State ,
OECD ,
Tax Reform ,
Tax Treaty
Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more
10/7/2015
/ Anson v HMRC ,
Business Taxes ,
Delaware Limited Liability Company Act ,
Dividends ,
Double Taxation ,
Foreign Corporations ,
HMRC ,
Limited Liability Company (LLC) ,
LLC Agreements ,
Tax Credits ,
Tax Treaty ,
UK ,
UK Supreme Court
Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more
9/29/2015
/ Anson v HMRC ,
BEPS ,
CFC ,
Cross-Border Transactions ,
Double Taxation ,
Entity Classification ,
HMRC ,
Legal Entity Identifiers ,
Limited Liability Company (LLC) ,
Tax Policy ,
Tax Treaty ,
UK ,
UK Supreme Court
On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more
Introduction -
Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more