Foreign Direct Investment Guidelines on LLPs

The Covid 19 crisis has impacted businesses in several respects: in many cases with the reduction of their profitability, changes in the working conditions of their management and teams via the use of digital tools or negotiation of financing to overcome the crisis.

Now multinational groups may need to consider a restructuring of their operations (taking into account relocation opportunities) and a review of their transfer pricing policy, a better identification of the places where the management or activity is performed or a refinancing of their operations.

Besides, in the near future, many new or potential rules are expected to modify the taxation of the digital industry (and could possibly affect other industries).

This webinar will address these post-Covid 19 tax challenges and, in particular, discuss the following:

1.Corporate tax challenges in the context of business restructurings / reorganizations:

Use of tax losses by reorganizing the group
Transfer tax issues
Nexus approach and IP utilization

2.Transfer pricing aspects 2021:

Remuneration of routine entities
Transfer and remuneration of intangible assets
Inter-company financing

3.Potential impact of home office on the places of management or establishments of multinational groups:

OECD analysis proposed in April 2020
Applicability in 2021?
Will the concepts of permanent establishments and effective place of management survive to the sanitary crisis ?

4.New tax environment for the digital industry:

Update on the works at OECD level
Implementation of a digital services tax in a number of countries
Potential new obligations imposed by DAC 7 on digital platforms