News & Analysis as of September 18, 2024

European Union › BEPS

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The European Union is an economic and political partnership comprised of 27 nations within the Eurozone. The EU was established in 1948 to promote stability and cooperation among member states in the aftermath of WWII. The EU maintains a common currency as well as several intranational institutions, including the European Parliament and the European Commission. less -

Proposed Amendments to Pillar Two Law in Luxembourg

Goodwin on 6/26/2024

On 12 June 2024, Luxembourg published a bill of law amending the law of 22 December 2023 (the Pillar Two Law[1]) implementing EU directive no. 2022/2523, largely known as the “EU Minimum Tax Directive” or “Pillar Two...more

Guiding Captives Through Global Developments

Conyers on 2/21/2024

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

New Multilateral Tax Treaty Implements the Subject to Tax Rule

Holland & Knight LLP on 10/5/2023

More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more

EU’s Ambition Beyond BEPS 2.0

Cadwalader, Wickersham & Taft LLP on 6/1/2021

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

The New UAE Economic Substance Regulations (Updated)

K&L Gates LLP on 1/6/2021

EXTENSION ANNOUNCED - The Ministry of Finance (MoF) announced on 31 December 2020 the extension of the deadline for submitting the ESR’s notifications and reports. All companies in the UAE that were engaged in any of the...more

The New UAE Economic Substance Regulations

K&L Gates LLP on 12/11/2020

Background - The European Union (EU) has a blacklist of countries that do not meet the EU’s criteria on tax transparency, fair taxation, and the implementation of measures to counteract base erosion of profit shifting (BEPS)....more

Economic Substance Regulations in UAE: Changes and their impact

Bracewell LLP on 9/22/2020

In response to a review of the UAE’s tax framework by the European Union and the UAE’s commitment to the Organisation for Economic Cooperation and Development (OECD) anti-Base Erosion and Profit shifting (BEPS) Action Plan,...more

EU Court Overturns Commission Decision in Landmark Apple Tax Case

Jones Day on 7/21/2020

The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...more

UAE Economic Substance Regulations – Self Assessment Notifications

Bracewell LLP on 6/16/2020

On 30 April 2019, the UAE Cabinet, in response to the European Union’s review of the UAE’s tax framework and the UAE’s commitment to the Organisation for Economic Cooperation and Development (OECD) anti-Base Erosion and...more

Cayman Islands Added To European Union Tax Blacklist

Morrison & Foerster LLP on 2/21/2020

The Council of the European Union confirmed on Tuesday, 18 February 2020 that the Cayman Islands, a British overseas territory, has been added to the European Union’s ‘blacklist’ of non-cooperative jurisdictions for tax...more

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

McDermott Will & Emery on 2/11/2020

The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Skadden's 2020 Insights

Skadden, Arps, Slate, Meagher & Flom LLP on 1/30/2020

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Taxing the digital economy - The ABCs of the secretariat proposal for a “unified approach under pillar one”

Eversheds Sutherland (US) LLP on 10/14/2019

On 9 October 2019, the Organisation for Economic Co-Operation and Development (OECD) published its latest public consultation paper in relation to its proposals to address the challenges of taxing the digital economy,...more

European Real Estate Finance: Recent developments – June 2019

White & Case LLP on 6/11/2019

As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

The Juncker Presidency and EU Tax Policy

Womble Bond Dickinson on 3/13/2019

In this reprint of his 2014 article, Rick leveraged his past working relationship to Jean Claude Juncker to accurately predict the unprecedented tax policy success of the Juncker Commission. Jean-Claude Juncker,...more

OECD Holding Public Consultation on the Tax Challenges of Digitalization

Akin Gump Strauss Hauer & Feld LLP on 3/12/2019

• Public consultation follows release of OECD discussion draft on potential tax changes to address difficulties in taxation caused by the digital economy. • OECD hopes to produce “consensus document” with proposed...more

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on 2/13/2019

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

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

Womble Bond Dickinson on 2/7/2019

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

Japan Legal Update - Volume 43 | December 2018/January 2019

Jones Day on 2/4/2019

Labor - Amendment to Immigration Control Act Introduces New Visa Categories - As of April 1, 2019, most provisions of the "Immigration Control and Refugee Recognition Act," which was amended in part on December 8,...more

UK Tax Round Up - October 2018

Proskauer Rose LLP on 10/30/2018

General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more

UK Tax Round Up - September 2018

Proskauer Rose LLP on 10/8/2018

UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

UK Tax Round Up - May 2018

Proskauer Rose LLP on 5/31/2018

General UK Tax Developments - Enterprise management incentive (EMI) options State Aid approval - We referred in the April UK Tax Round Up to the expiry of the EU's State Aid approval for EMI options. Fortunately, this...more

Asset Management Regulatory Roundup - April 2018 - Issue 7

Dechert LLP on 4/20/2018

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s statement on the implementation period for Brexit; the requirement for firms...more

EU Targets Tax Avoidance Reporting Obligations for Intermediaries

Jones Day on 4/3/2018

The Situation: The Member States of the EU have unanimously agreed on a proposed directive establishing new and far-reaching tax reporting obligations for "intermediaries" and taxpayers. The Result: The proposal lays down...more

UK Tax Round Up - December 2017

Proskauer Rose LLP on 12/29/2017

Finance (No. 2) Bill 2017-19 - The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more

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European Union › BEPS

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