MULTINATIONALS

Sarah Ling

BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).

Brin Rajathurai

Lorand Bartels

The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).

Rhiannon Kinghall Were

Lucy Urwin

Rhiannon Kinghall Were and Lucy Urwin (Macfarlanes) consider what the agreement means for the international taxation of multinationals.

Constantine Christofi

Adam Craggs

Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

Jack Prytherch

Jack Prytherch (Bird & Bird) discusses what HMRC will look for in an investigation and the steps MNEs can take to protect themselves.

Ken Almand

Paul Daly

Changes in transfer pricing policies may be required as a result of the impact of Covid-19, as Ken Almand and Paul Daly (BDO) explain.

Daniel J. Pugh John W. Lamszus Selena Schneider

Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.

Stuart Pibworth

Jenny Doak

Jenny Doak and Stuart Pibworth (Weil, Gotshal & Manges) revisit some of the key UK corporation and withholding tax considerations to consider on guarantees of financial obligations.

Karen McGrory

Karen McGrory (BDO) answers a query on the tax issues facing large multinationals when its employees travel internationally within the group.

Julie Hughff

Andy Baillie

It is a year since the BEPS Action 13 final report was published. Julie Hughff and Andy Baillie (KPMG) examine the practical issues facing multinational groups.

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