Norway

Arbitration, Arm's Length, BEPS, Double Taxation, International Tax Law, MAPs and APAs, Norway, OECD, OECD MC Convention, Permanent Establishments, Tax Treaties, Transfer Pricing, UN Tax Convention, United Nations

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

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD gathers and publishes statistical data on such cases separate from all other kinds of tax treaty disputes. Recourse to MAP to…

COVID-19, Digitalization, Norway, OECD, Permanent Establishments, Physical presence

(Wolters Kluwer)/ /Leave a comment

The global COVID-19 pandemic that arose in early 2020 could be considered the most disruptive factor the world has witnessed in generations. Paradigms taken for granted until then were upended, resulting in a ‘new normal’ that has changed the way we do business. As with all facets of business, international taxation also came under increased…