MNE Profits

BEPS, Digitalization, Equalization levy, India, International Tax Law, MNE Profits, OECD, Permanent Establishments, Tax Avoidance, Tax Policy, Tax Treaties, Uncategorized, United Nations

(Advocate)/ /Leave a comment

Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD as part of its 15-point Action Plan to tackle base erosion and profit shifting. The Indian government, too, introduced two key…

Alienation of Shares, Double Taxation, International Tax Law, M&A and Reorganizations, MNE Profits, OECD, Real Estate, Tax Treaties, United Nations

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

Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of income earned and the tax classification and entitlement to treaty benefits of investment funds. Real property gains This time I consider two…

BEPS, Digitalization, MNE Profits, OECD

, (Squire Patton Boggs)/ /Leave a comment

On June 9, 2019 the G20 finance ministers endorsed the program of work that was issued by the OECD’s Inclusive Framework on BEPS on May 31, 2019 in relation to tax challenges arising from the digitalization of the economy. As expected, the program of work has two parts. The first part, called Pillar One, aims…

Germany, MNE Profits, Tax Policy

, (University of Muenster)/ /Leave a comment

According to an undisclosed policy paper that is currently circulated within the OECD, the German government is promoting an internationally coordinated reform of corporate taxation. Specifically, Germany proposes an effective minimum tax on the profits of multinational companies. Complex, easy to manipulate and unfair – there is widespread discontent with the current system of international…