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ARTICLE · 01 AUGUST 2017

Transfer Pricing Times: 2017 Tax Reform - Transfer Pricing Opportunities?

In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide

GlobalTax

In this edition: 2017 tax reform, important new requirements for Luxembourg finance company tax rulings and ATO hubs practical compliance guide

2017 Tax Reform - Transfer Pricing Opportunities?

Corporate tax reform sits near the top of the agenda for both the Trump administration and the Republican controlled House of Representatives. Areas where both parties agree include:

  • Tax Rate Reduction;
  • Repeal of Corporate AMT, and;
  • Tax Breaks for Repatriation of Foreign Earnings.

Border Adjustments is another area for potential reform that both Congress and the President have spoken to. Potentially a fundamental shift in the U.S. corporate tax system, Border Adjustments would have the effect of converting the U.S. system of taxing worldwide income to a territorial tax system. Congress has a border adjustment tax explicitly within the House Republican blueprint, while president Trump has said that Border Adjustments are "still on the plate" without endorsing

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