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The Evolving World of Global Tax Planning

In October 2015, final recommendations on Base Erosion and Profits Shifting (BEPS) were released, setting in motion epochal changes that will impact the global effective tax rate (ETR) of multinational enterprises (MNE) in the coming years.

Country-by-Country Reporting (CbCR) is the first, almost globally adopted output of the BEPS process currently facing MNEs. It raises some potentially far-reaching questions with respect to traditional operating models and supply chain structures, and also affects the future of cross-border dispute resolution. Harnessing the potential upsides and downsides of these and the other evolutions will be a driver of the future ETR of MNEs.

View the five-minute video below, in which McDermott lawyers discuss the implications of Country-by-Country Reporting for MNEs.




Transfer Pricing Developments – A Year in Review

Transfer pricing, the allocation of income or loss between members of a controlled group, (TP) continues to be the critical taxation issue in the cross-border world (international, federal or state), whether in planning, controversy or other purposes. Why is this case? Because the tax consequences of each entity begins with its income or loss posture.

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