November 2016
International Legal Highlights | November 2016 1
The New World of Global Tax Planning: a
Checklist for Success
Cym H. Lowell (Dallas)
As all multinationals (MNEs) are discovering, domestic implementation of the
recommendations set out in the base erosion and profit shifting (BEPS) final
reports from 2015 has the potential to significantly impact their effective tax
rate planning.
The immediate issue flows from the country-by-country (CbC) transfer pricing
(TP) documentation process. Many countries (including China, Japan, Italy
and the United Kingdom) have implemented domestic legislation effective for
2016, and the United States has finalized regulations that will come into effect
in 2017. A multilateral instrument relating to CbC is well underway, and is
expected to impose the CbC requirements on all 3,000+ existing treaties.
Table of Contents
1 The New World of Global Tax Planning:
a Checklist for Success
3 Using Licenses and Settlement
Agreements to Determine Patent
Damages in the United States
4 Full-Function Joint Ventures in the
European Union
6 Brexit: Competition Law Implications for
Japanese Companies
Welcome to the next edition of McDermott International Legal Highlights.
This publication includes a collection of articles written by McDermott
lawyers in the US and Europe focusing on recent and future legal
challenges that Japanese companies may face while expanding abroad.
We are reporting on topics relevant for Japanese companies where
McDermott has special skills and deep experience.
We hope that you enjoy these legal news updates. Please feel free to
contact your McDermott attorney or me if you have further questions or
require clarifications.
Jacques Buhart
Partner
Paris, Brussels
McDermott Will & Emery
