INTRODUCTION Contributed by: Devon M. Bodoh, Joseph M. Pari and Blake D. Bitter, Weil, Gotshal & Manges LLP
some tax provisions related to individuals. Accord - ingly, a significant portion of US corporate tax struc - ture remained largely the same and the basic princi - ples underlying US corporate taxation are essentially unchanged. Consequently, while there certainly are developments and changes that constantly occur, the US corporate tax system has remained fairly stable pending the application of Pillar Two to US multina - tional groups. As readers go through this guide, they may find a similar situation in a number of jurisdictions. In other words, while there may be a significant and real feeling of chaos and uncertainty, there are pockets of stability that can provide guidance and relative comfort when evaluating investment in an unfamiliar jurisdiction. This guide is divided by jurisdiction before being bro - ken down further into the following sections that detail key features of each jurisdiction’s tax system: • corporate structures, residence and tax treatment; • corporate tax regime; • taxation of corporations and non-corporate busi - nesses; • taxation of inbound investments; • taxation of non-local corporations; • taxation of foreign income of local corporations; • anti-avoidance provisions; • audit cycles; and • the application of BEPS.
These sections provide important background and insights into the implications of, and important con - siderations for the form of, investment into an unfa- miliar jurisdiction. Furthermore, as users of this guide proceed on a jurisdiction-by-jurisdiction basis, they can discern key points of consistency and diver - gence between different jurisdictions, thus allowing for a clear comparison when contemplating where to operate or invest. Conclusion What is clear on the global tax stage is that taxpayers and tax practitioners will continue to grapple with sig - nificant uncertainty about the global tax system and how non-tax factors (like global and US politics) will shape how jurisdictions approach a globally coordi - nated tax system. Nevertheless, this guide provides necessary information and tools to deal with such uncertainty and act with confidence when investing in and operating a cross-border enterprise.
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