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The Supreme Court in Odfjell Rig (case Rt-2015-1360) concluded that the limited activities carried out onshore were not sufficient to create the taxable nexus to Norway that would be necessary for tax to apply to the income deriving from a bareboat charter.

The US “fully expects” to have finalised its country-by-country reporting (CbCR) rules by June 30, according to Robert Stack, Treasury deputy assistant secretary for international tax affairs.

The US will finalise its country-by-country reporting (CbCR) rules by July, according to Robert Stack, Treasury deputy assistant secretary for international tax affairs.

Over the next three weeks, Ravi Lakdawala, transfer pricing lead at Bayer India, explores how taxpayers can implement a successful TP lifecycle from the planning stage to submitting documentation.

Adam Eagers and Mark Bennett look at the impact BEPS has had on the M&A market and discuss the commercial and operational aspects of any changes for investors.

Global tax rules are changing, and changing rapidly. The final reports on the Base Erosion and Profit Shifting (BEPS) Action Plan have been released by the Organisation for Economic Cooperation and Development (OECD) and endorsed by the G20. These reports on the 15 BEPS Action Points recommend significant changes in international tax laws and treaties. Due to the unique global alignment on the matter, BEPS is the most comprehensive change in international taxation in history. Attention has turned to the actions that are being taken by countries in response to these recommendations.

Sarah Churton, Ellis Lambert and Ian Dennis explain how the BEPS Action Plan is changing the tax landscape for intangible assets, and what this means for taxpayers.

Shaun Lucey and Ariana Kosyan provide a comprehensive review of the way financing and treasury functions will be affected by Actions 2, 4, 5, 6, 8, 9, 10, 13 and 15 of the BEPS Project.

Joost Vreeswijk and Ai-Leen Tan examine the impact that BEPS Action 7 will have on centralised operating models, and look at changes which multinationals should be considering to guard against exposure to the new rules.

Ronald van den Brekel and Tim Meijer analyse the compliance-related challenges which companies face, and how they can best allocate their resources to deal with them.