Double Taxation

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Double Taxation

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NJ Tax Court: Extraterritorial income not subject to Corporation Business Tax

This briefing examines the recent judgment by the New Jersey Tax Court, concerning Infosys Limited of India Inc.

Law Firm: Reed Smith | Published: 04 December 2017 | Practice Area: Corporation Tax

India publishes new rules for master file and CbC reporting

Acting on its commitment to the OECD BEPS Action Plan, India has published the final guidance in relation to the requirements of multinationals to provide master file and country-by-country (CbC) reporting in India.

Law Firm: DLA Piper | Published: 01 December 2017 | Practice Area: Central Government

Japan's National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

The Japanese National Tax Agency has released guidance for taxpayers on the mutual agreement procedure. This briefing examines its contents.

Law Firm: DLA Piper | Published: 01 November 2017 | Practice Area: Cross-border: Commercial and International Trade

European Union adopts new Directive to better resolve double taxation disputes

The Council of the European Union adopted the Tax Dispute Resolution Mechanism Directive on 10 October 2017. This article examines some of the key objectives of the new rules under the Directive.

Law Firm: DLA Piper | Published: 18 October 2017 | Practice Area: Central Government

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OECD releases reviews on BEPS Action 14

The OECD has released analyses of individual country efforts to improve dispute resolution mechanisms. This article examines the efforts of Belgium, Canada, the Netherlands, Switzerland, the UK and the US.

Law Firm: DLA Piper | Published: 12 October 2017 | Practice Area: Non Governmental Organisations

Digital economy taxation: a new counter-productive EU initiative?

Paris, Berlin, Madrid and Rome are preparing a reform proposal aimed at fighting against the tax optimisation practices of GAFA.

Law Firm: Gowling WLG | Published: 06 October 2017 | Practice Area: Taxation

Hong Kong releases Consultation Report on Measures to Counter Base Erosion and Profit Shifting: key topics

The Consultation Report sheds light on the legislative changes to come and the respective timelines, allowing companies to assess how these BEPS-driven changes may affect their group structure and strategic plans.

Law Firm: DLA Piper | Published: 28 September 2017 | Practice Area: Central Government

The proposed US tax reform: repatriation alternatives for multinationals operating in Latin America

A review of regulations in Argentina, Chile, Colombia, Mexico and Peru and steps for multinationals to consider regarding their operations.

Law Firm: DLA Piper | Published: 28 September 2017 | Practice Area: Double Taxation

Spain requires real-time submissions of VAT information

Large enterprises operating in Spain are coming to terms with the latest requirements to file their VAT information on a real-time basis through a new online system. This article examines the new setup.

Law Firm: DLA Piper | Published: 10 July 2017 | Practice Area: Banking and Finance

The Mutual Agreement Procedure: A taxpayers' tool reinvented

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This article examines the trend.

Law Firm: DLA Piper | Published: 07 July 2017 | Practice Area: Double Taxation

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