Perspective

HMRC Issues New Guidance on UK’s Diverted Profits Tax

On November 30, HM Revenue & Customs (HMRC) issued new interpretive guidance on the UK’s diverted profits tax (DPT) found in Part Three of the Finance Act 2015, which is intended to apply to large multinational enterprises (MNEs) with business activities in the UK that enter into “contrived arrangements” to… Read more »

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Despite BEPS, Speed Remains Top Global Tax Challenge

The OECD’s Base Erosion and Profit Shifting (BEPS) initiative is progressing toward a crucial phase during which U.S. policymakers will balance its priorities with their own agendas. This initiative will doubtlessly create new concerns as well as new opportunities for multinational companies whose businesses transcend borders. But necessary preparation for… Read more »

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Understanding BEPS and the Impact of Country-by-Country Reporting

The rise of the digital economy coupled with increased globalization and more fluid movement of capital has undeniably changed the way multinational corporations operate, providing them with immeasurable opportunities for global tax planning. With tax regulations still grounded in the past with little regard for intangibles or global risk management,… Read more »

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State Tax Incentives Become Bargaining Chips in a Globally Mobile Economy

There once was a time when a business’ headquarters location was based on proximity to natural resources and transportation networks. If you owned a mill, you worked near a river. If you exported goods, you were near a port. While some of those geographical limitations still exist, most businesses operating… Read more »

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An Opportunity at the Intersection of Transfer Pricing, Customs, and Indirect Tax

Within your global supply chain, transfer pricing, customs, and indirect tax are undeniably connected. Each step in the global supply chain is intertwined—from setting the transfer price and customs import valuation to goods receipt and invoicing. As a result, changes in one link affect the next, which illustrates the value… Read more »

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Determining Taxability in the Ever-Evolving World of e-Commerce

In a world of rapidly evolving technology, e-commerce transactions have become the norm. While the term e-commerce initially referred to Internet-based sales of physical items, recent years have given rise to a new breed of purely electronic transactions including cloud computing, digital downloads, streaming entertainment, and information services, which have further… Read more »

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