Company

Abuse of law, Anti-tax avoidance, ATAD, Beneficial ownership, BEPS, Canada, Company, Developing Countries, Directive, Double non-taxation, Double Taxation, Holding company, International Tax Law, MLI, OECD MC Convention, Principal purpose test, Tax Avoidance, Tax haven, Tax Treaties, Treaty shopping, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /Leave a comment

The Judicial Committee of the Privy Council (the highest appeal court for a number of Commonwealth countries) ruled  last month that payment rapid payment of dividends by a Trinidadian company  through a chain of intermediate holding companies as required by the ultimate parent company in Canada was not artificial or fictitious for purposes of Trinidad’s…

Arm's Length, Company, Developing Countries, Direct taxation, Double Taxation, Finland, income tax, India, International Tax Law, MNE Profits, MNEs, OECD, OECD MC Convention, Permanent Establishments, South Africa, Tax Treaties, Transfer Pricing, UAE, UN Tax Convention, Uncategorized, United Kingdom, United Nations, United States

(Temple Tax Chambers; King’s College London)/ /1 Comment

“When I use a word,” Humpty Dumpty said in rather a scornful tone, ” it means just what I choose it to mean, neither more nor less.” (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD’s 10 year project on attribution of profits to permanent establishments, there were very few reported cases on…

Company, Corporate tax policy, OECD MC Convention, Permanent Establishments, UAE

, (Aurifer) and (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /2 Comments

Corporate Taxation (CT) Federal Decree No. 47 of 2022 (UAE CT Law) Federal Tax Authority (FTA) Ministry of Finance (MoF) OECD MC Convention (OECD MC) Permanent Establishment (PE) United Arab Emirates (UAE) UN MC Convention (UN MC) 1. Introduction The United Arab Emirates (UAE) announced the introduction of a Corporate Taxation (CT) regime on 31 January…

Company, Directors' Services, EU, Taxable persons, UAE, VAT

(Head of Tax Strategy for Careem and Author of ‘Fundamentals of GCC VAT Law’) and (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

Should services performed by a member of a board of directors towards the company of which s/he is a member be subject to VAT? This is a question that keeps many VAT legislators, authorities, and advisors around the world busy. It is an area that has seen numerous changes in tax policy, sometimes as a…