In recent years there has been a great deal of interest in corporate migrations out of the UK. But a non-UK group becoming UK headquartered is an area that has received somewhat less attention. Simon Letherman, Ansgar Simon, Don Lonczak and Iain Scoon of Shearman & Sterling in London and New York explore why US groups are attracted by inverting into Europe, and particularly the UK.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief