ETR
Subscribe to ETR's Posts

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.

Continue Reading

Globalism vs. Populism in the International Tax World

Adoption of the base erosion and profit shifting (BEPS) action items in specific countries can be expected to alter traditional multi-national enterprises (MNE) tax strategy processes. In this regard, it is appropriate to note that tax authorities and the Organization for Economic Co-operation and Development (OECD) often seem to overlook, or conveniently ignore, that MNE strategies are often a function of the rules established by countries to develop their own tax base (at the expense of other countries). In other words, countries, in their respective self-interests, grant incentives of various sorts to encourage economic investment. MNEs take advantage of these incentives to minimize their tax liabilities, which the BEPS process views as, somehow, inappropriate behavior of MNEs denuding the tax base of other countries. Like water going downhill, MNE planning strategies will utilize the most efficient path to achieve desired objectives. This is a fiduciary...

Continue Reading

STAY CONNECTED

TOPICS

ARCHIVES