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Results: 1-10 of 68

Base-erosion and profit-shifting OECD report

  • McDermott Will & Emery
  • -
  • Global
  • -
  • May 14 2013

In February, the Organization for Economic Co-operation and Development (OECD) released its long-awaited report on base-erosion and profit-shifting

Standards, patents and antitrust: what are the risks?

  • McDermott Will & Emery
  • -
  • Global
  • -
  • May 9 2013

It is important that members of standard setting organisations (SSOs), owners of standard essential patents (SEPs) and licensees of such patents

Global transfer pricing: U.S. trending

  • McDermott Will & Emery
  • -
  • Global, USA
  • -
  • April 5 2013

The U.S. is on the rise. The Internal Revenue Service (IRS) recently released its 2012 statistics on Competent Authority proceedings. For the first

What do we do now that the world didn’t end in 2012?

  • McDermott Will & Emery
  • -
  • Global
  • -
  • February 7 2013

The countdown to the launch of the new generic top-level domains, or gTLDs, and the surrounding uncertainty about whether the potential commercial

Tax base erosion: who is guilty?

  • McDermott Will & Emery
  • -
  • Global
  • -
  • January 23 2013

It is rare that global transfer pricing strategies of multinational enterprises (MNEs) find their way onto front page coverage in financial center

OECD transfer pricing safe harbors

  • McDermott Will & Emery
  • -
  • Global
  • -
  • December 20 2012

The factual nature of transfer pricing (TP) determinations can be an extremely complex subject that frequently vexes both taxpayers and tax administrations alike

International trade actions complicate global market for renewable energy businesses, particularly in the solar sector

  • McDermott Will & Emery
  • -
  • China, European Union, Global, USA
  • -
  • December 3 2012

As a result of several recent actions, developers of solar energy projects may face increased costs

The OECD fights multinationals over transfer pricing for intangibles

  • McDermott Will & Emery
  • -
  • Global
  • -
  • November 28 2012

On 6 June 2012, the Organisation for Economic Co-operation and Development (OECD) released a discussion draft entitled “Revision of the Special Considerations for Intangibles in Chapter VI of the OECD Transfer Pricing Guidelines and Related Provisions”

International arbitration: why to agree to it and how to avoid going through with it

  • McDermott Will & Emery
  • -
  • Global
  • -
  • November 28 2012

The advantages of arbitration over national court litigation for resolving disputes under international agreements are well known

Effective resolution of BRICs country transfer pricing disputes

  • McDermott Will & Emery
  • -
  • Global
  • -
  • November 9 2012

In the evolving world of international transfer pricing, it can be risky to assume that planning strategies to achieve the lowest possible effective tax rates, as encouraged by the operative provisions of the Organisation for Economic Co-operation and Development and the UN Model Treaties, will necessarily be effectiveor respected

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