Developing Countries

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…

Amount A, Developing Countries, Digital economy, OECD, Pillar I

(Reader in Tax Law, King’s College London )/ /Leave a comment

Reader in Tax Law, King’s College London (Autumn 2024) The past 30 June 2024 was anticipated to be a historic moment. Inclusive Framework’s (IF) countries, both developed and developing, were expected to publicly commit to a crucial element of the “global tax deal” by signing the Multilateral Convention (MLC) for the OECD Pillar One. Expectations…

Airlines, Developing Countries, OECD, Shipping, United Nations

, (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention between Developed and Developing Countries (“UN Model 2021”)[1] offers two alternatives under Article 8. Alternative A aligns with the OECD Model Tax Convention on Income and…