On 19 September 2023, the EU Commission opened a consultation on its BEFIT Directive, which was published the previous week. BEFIT is the acronym for Business in Europe: Framework for Income Taxation. The initiative, widely considered to replace the EU Commission’s Consolidated Common Corporate Tax Base, will aim to introduce a common set of rules for groups of companies and head offices, based in the EU, to determine their taxable base. The BEFIT proposal could also apply to non-EU-headquartered groups.

Amount B was introduced as a “fixed return” on “baseline marketing and distribution activities” in the October 2020 Blueprint of Pillar One, and was seen as a critical component of the Pillar One deal
Following the long-awaited release of the consultation document on 8 December 2022 and subsequent public commentary received, the OECD/G20 Inclusive Framework on BEPS published a consultation document on Amount B on 17 July 2023, creating renewed momentum and putting Amount B back into the international tax spotlight.

In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to Section 163(j) effective for tax years beginning after December 31, 2017. On December 28, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (“Proposed Regulations”) implementing the amendments to Section 163(j)…

Baker McKenzie’s EMEA Tax Practice Group presented an overview on “Digital Tax”, the third in a series of short webinars to keep tax professionals abreast of recent developments in these less than certain times on 23 June 2020.

The COVID-19 outbreak has led many countries to implement border controls as a temporary measure to curb infections, and many employers find their employees working from home or in locations outside the jurisdictions where employers typically operate or are located. International travel restrictions affect Boards of Directors and employees of…