After the first post on BEPS, I decided to go laterally and approach an issue that may resonate to many tax practitioners but unfortunately is not so widely discussed perhaps because of its interdisciplinary impacts – what are the consequences and limits for this “rush” towards massification of tax information data retrieval and exchange. We…

The world is following with attention the developments of one of the major all-time corruption scandals, involving one of the symbols of the Brazilian economy, Petrobras. If it was not enough fuzz, now the Federal tax authorities are facing another problem, which is rumor of corruption within the Administrative Court of Federal Tax Appeals (“CARF”)….

It is well known that case law from the European Court of Justice (ECJ) imposes limitations on the application of anti-avoidance rules by Member States. Accordingly, it is of vital importance that recommendations made under the OECD project on base erosion on profit shifting (the BEPS project), are adaptable, where necessary, to enable Member States…

In July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting, aimed at ensuring the coherence of corporate income taxation at the international level. Action 3 of the Plan stressed the need to address base erosion and profit shifting through CFC rules, since then existing domestic CFC rules do not always…

When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19. What about employees of international organisations? Although international civil servants, they work for no government and are outside Art 19. Commonly, treaties…

One of the most polemical tax measures in Colombia’s recent taxation history has undoubtedly been the introduction of the Financial Transactions Tax (FTT). Loved by the public administration but hated by the taxpayers, this tax highlights the very difficult problem of whether it is possible to combine both a high degree of efficiency and an…

In my previous post, I discussed the budget law related reform updates in China. This post continues such discussion by reviewing issues of China’s tax administration and transfer payment systems. Tax Administration and Collection  China’s tax administration and collection system is unique in two ways. First, over 70% of the tax revenue is generated through…

I ”grew up” believing that publications of the OECD are the bibles of taxation.  They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple interpretations.  My multiple contacts with the OECD over several years strongly nuanced that view. First, there were the invitations to congresses:…

“You never want a serious crisis to go to waste”, Rahm Emanuel, Chicago Mayor (and former Obama White House chief-of-staff) Fundamental reforms are always controversial and the G20/OECD hard-pressed Base Erosion Profit Shifting project is no exception to this rule. They shake with presumed principles, they provoke a wide debate, they alarm businesses if they…

The OECD-G20 BEPS Project’s goal is ciclopeous: Making the global tax environment fairer than ever by closing loopholes and adopting rules of international law which would be domesticated simultaneously and uniformly by all participating Nations; and all of that with the aim of making the global enterprise accountable for taxes at source (markets) and home,…

“When the map and the territory don’t agree, always believe the territory”  Gause and Weinberg – describing Swedish Army Training Easier said than done Tax risk management in Africa reminds me of how the first explorers having to navigate the new world  must have felt. Not having any decent maps and often creating their own…