7/1/2025 2:01:51 PM Section 899 compromise shifts international tax landscape By Zoe Andrews Tanja Velling The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...
2/21/2025 12:21:13 PM French Finance Bill for 2025: what will be new for businesses? By Sébastien de Monès Victor Camatta After a chaotic process marked by the no-confidence vote of the Government formed by the French Prime Minister Barnier in December 2024...
7/11/2024 9:47:01 AM Fourth tranche of Pillar Two Administrative Guidance: all clear for securitisations? By Alex Sim Tanja Velling Securitisation is a form of structured financing, whereby the credit risks associated with a specific pool of assets are segregated from...
1/12/2024 11:38:56 AM Everyone's a winner - but some wins are more substantial than others: latest OECD assessment of the impact of the global minimum tax By Zoe Andrews The global minimum tax is now in effect in the UK for qualifying multinational groups for accounting periods beginning on or after 31...
9/27/2023 1:34:09 PM Where are you on Pillar Two? By Zoe Andrews Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...
1/12/2022 3:31:42 PM Full steam ahead for the UK’s implementation of the global minimum tax rules By Zoe Andrews When is the best time to consult on the UK’s implementation of the OECD/IF GloBE model rules published on 20 December 2021 with the aim...
1/5/2022 11:13:10 AM The Spanish minimum 15% CIT rate: at the vanguard of the OECD/IF tax reform or in breach of a global agreement? By Teresa Morales For tax years starting as of 1 January 2022 or later, a minimum effective 15% Corporate Income Tax (CIT) will apply to large Spanish...
12/21/2021 4:42:47 PM Global minimum tax model rules By Zoe Andrews The model rules for Global Anti-Base Erosion (GloBE) (a.k.a. Pillar Two of international tax reform) set a template for a...
10/8/2021 2:29:23 PM Ireland agrees to sign up to the OECD Inclusive Framework political agreement on the OECD two-pillar approach By Paul Fahy Bryan Hughes Ireland will sign up to the OECD Inclusive Framework political agreement on the two-pillar approach, following approval by the Irish...
5/19/2021 10:26:18 AM From CCCTB to BEFIT: the European Commission's plan to future-proof taxation By Tanja Velling The Commission's Communication on Business Taxation for the 21st century sets out reams of important tax policy announcements, whilst...
1/20/2021 3:19:30 PM Pillar Two: simplification is key By Tanja Velling Simplification was a key theme of the public consultation on the OECD’s two-pillared international tax reform proposal. Zoe Andrews has...
10/16/2020 12:35:32 PM International tax reform – winners and losers By Zoe Andrews The OECD's Impact Assessment presents its international tax reform proposal as the least worse-case scenario rather than a significant...
10/16/2020 12:00:00 AM Pillar Two: Is the cure worse than the disease? By Andrea Manzitti Francesco Saverio Scandone During OECD Tax Talks #17, Pascal Saint-Amans presented the Pillar One and Two Blueprints as a glass half-empty because no consensus has...
10/12/2020 11:10:04 AM OECD pushes back deadline for international tax reform By Tanja Velling The OECD has published blueprints for a solution to the tax challenges arising from the digitalisation of the economy and acknowledged...
2/14/2020 12:00:00 AM International tax reform could increase global tax revenues by up to 4% By Zoe Andrews While discussions continue on the design and technical detail of international tax reform under Pillars One and Two, the OECD Secretariat...