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Observations on Notice 2023-80: The Treasury Department and IRS' Preliminary Guidance on the Interaction of Foreign Tax Credit and Dual Consolidated Loss Rules With Pillar Two Taxes and the Extension of Notice 2023-55 Relief Period | Skadden, Arps, Slate, Meagher & Flom LLP

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice)...
United States Department Of The Treasury Multinational Enterprise Group Meagher Flom Erosion Model Rules Pillar Two Globe Organization For Economic Cooperation

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Global Tax System Sees Sweeping Overhaul by OECD/G20 Members

137 members of the OECD/ G20 IF on BEPS agreed to a sweeping overhaul of the global tax system by way of a two-pillar solution. This agreement to prevent BEPS is envisaged to transform a century old international taxation system by the adoption of the Two-pillar Solution.
Janet Yellen Engineering Analysis Centre Of Excellence Private International Tax Cooperation Erosion Model Rules Pillar Multilateral Convention Group On Tax

Profit-linked intra-group service charges: An Indonesian perspective

Sandra Suhenda, Beatrice Simamora and Kartika Sukmatullahi Hasanah of Deloitte Indonesia take a practical look at what Indonesian taxpayers can expect on transfer pricing issues pertaining to profit linked intragroup service and how they can prepare to navigate through these challenges.
Sandra Suhendais Sandra Suhenda Kartika Sukmatullahi Hasanah Beatrice Simamora Tax Court International Tax Law

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