Double Taxation

BEPS, Double Taxation, Intangibles, OECD, Tax Avoidance, Tax Policy, Tax Treaties, Transfer Pricing, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /2 Comments

Taxation of the digital economy featured in discussion on the implementation of the OECD/G20 BEPS action items at the annual conference of the Canadian Tax Foundation in Toronto on 21 November 2017. Several speakers note that no generally accepted solution had been found to address the impact of the digitalisation of the global economy on…

Arbitration, BEPS, Double Taxation, EU/EEA, MAPs and APAs, MLI, OECD, Tax Treaties, Transfer Pricing

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

Adoption of the EU Council Directive on Tax Dispute Resolution Mechanisms in the European Union on 10 October 2017 is a milestone in international tax dispute resolution. The Directive offers a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum standard, and largely renders the arbitration…

Arbitration, Double Taxation, EU/EEA

(KPMG Meijburg & Co)/ /Leave a comment

On 12 September 2017, the CJEU confirmed that it has jurisdiction over a dispute between Austria and Germany regarding the interpretation of a double tax convention entered into between the two Member States under article 273 TFEU.[1]CJEU 12 September 2017, case number C-648/15, Opinion delivered by Advocate-General Mengozzi on 27 April 2017. The case was…