At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations over the past thirty years (since 1987).[1] This accumulated income, if distributed, would be taxed in the hands of the American shareholders. However, because Congress cannot…
Sustainability has become a global imperative in recent years, driven by the realization that societies are on the brink of potentially irreversible environmental, economic, and governance collapse. Given the central role of law in shaping commercial activity that impacts communities and the planet, it is crucial to analyse the question of how various legal frameworks…
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…
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…
What does the notion of “aggressive tax strategy” mean for the quest for tax justice and what are its consequences on environmental, social and governance matters?[1] In my opinion, an enterprise’s tax strategy should be considered when assessing whether that enterprise meets the so-called “ESG” criteria. I explain why in this blog. A justification for…
Introduction: some uneasy questions Taxation is at the core of the UN 2030 Agenda since it is an essential element to build a more equal, as well as more prosperous, society and provides the “fuel” needed to realize all the ambitious plans required to decrease our impact on the environment.[1] Therefore, good tax governance is…
