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Macfarlanes LLP | European Union, OECD, United Kingdom | 23 May 2022

Tax developments impacting investment fund managers

HMRC updated their guidance in relation to s103KE TCGA 1992, a clause which is designed to prevent double taxation arising on carried interest. The…
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Macfarlanes LLP | Cyprus, European Union, OECD, etc. | 19 May 2022

Unpacking Pillar Two: EU implementation

It might have been thought that EU Member States would be early adopters of the global minimum tax. All, apart from Cyprus, are part of the OECD…

Skadden Arps Slate Meagher & Flom LLP | OECD | 18 May 2022

The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis

In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most…
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A&L Goodbody | Ireland | 17 May 2022

Irish Revenue Commissioners 2021 Annual Report

2021 net Exchequer receipts came to €67.5bn, an increase of 20% (€11.3bn) from 2020. This increase in receipts was primarily driven by increases in…
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Machado Associados | Brazil | 13 May 2022

End of Libor impacts Brazilian transfer pricing controls

Several changes to benchmark settings published by the Intercontinental Exchange Benchmark Administration may have a direct impact on transfer pricing (TP) calculations performed for loans that are granted by and to Brazilian legal entities. As such, Brazilian companies should evaluate whether it is necessary to adjust loan agreements that are currently in place and verify whether additional......
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Pearl Cohen Zedek Latzer Baratz | Israel | 12 May 2022

The Madingo Court Ruling

Israel court rejects Israel’s Tax Authority business restructuring claim - and finally criticizes the ITA’s aggressive approach against foreign…
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Gowling WLG | Canada | 12 May 2022

Recent transfer pricing audit trends - CRA zeroes in on intercompany loans

The non-arm's length transactions which can be subject to Canadian transfer pricing legislation include tangible products, intangibles, intra-group…
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Loyens & Loeff | European Union, Global, Netherlands | 12 May 2022

Loyens & Loeff’s 8th Annual International Tax Developments Seminar

During the 8th Annual International Tax Developments Seminar, several Loyens & Loeff tax Experts as well as officials from the Dutch Tax Authorities…
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Clyde & Co LLP | European Union, OECD, United Kingdom | 11 May 2022

Internationally mobile employees: UK tax considerations

In recent years, arrangements involving employees in one country remote working for an employer in another country and international secondments have…
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Herzog Fox & Neeman | Israel | 10 May 2022

New Israeli Ruling Rejects Tax Authority’s Position Regarding Change of Business Model

The Tel-Aviv District Court recently issued its ruling in the Medingo case in which the court was asked to…
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