Inter-group financing by MNEs faces imminent change in the US

March 23 2017

The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

Female hand with megaphone on white background

Why in-house tax teams should do their own PR

Heads of tax need to push their teams forward as strategic business advisers to add value across the organisation, says Sandy Markwick

Sandy Markwick, April 25 2025

Direct Tax

This week in tax: Elon Musk and Treasury secretary clash over IRS leadership

Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm

Tom Baker, April 25 2025

Transfer Pricing

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025

Transfer Pricing

Fixing Italy’s approach to taxing digital business

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

Stefano Simontacchi , April 23 2025

Direct Tax

Copy of What Corporates Want 2025 (1).png

Asian clients unimpressed with firms’ team depth, exclusive data reveals

ITR’s research shows that in-house tax counsel in Asia also feel underserved by their advisers’ international networks

Tom Baker, April 22 2025

Direct Tax

World Tax and ITR Awards: how to write a winning submission

World Tax global head of research Jon Moore tells ITR how his team spots standout submissions, and gives early statistical insights into this year’s entries

Tom Baker, April 21 2025

Direct Tax

This is the Australian Parliament House in Canberra. Which was t

Tax advisory regulation would be slashed under Aussie conservative government

Australia’s conservative opposition will repeal controversial tax agent reporting rules if elected in the country’s May general election

Tom Ravlic, April 18 2025

Direct Tax

This week in tax: Gary Shapley tipped to become acting IRS commissioner

Shapley would be the fourth person to hold the job this year; in other news, UK tax advisory firm MHA raised fewer funds than expected from its London IPO

Tom Baker, April 17 2025

Transfer Pricing

‘General pause’ on pillar one in many countries: BDO tax leader

The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says

Sam Sholli, April 17 2025

Direct Tax

EY’s regulatory troubles continue as FRC launches Post Office probe

The UK regulator is investigating EY’s auditing of the national postal service as it relates to the high-profile Horizon scandal, which saw hundreds wrongfully convicted

Tom Baker, April 16 2025