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(Bomchil)/ /2 Comments

The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI)[1]http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf); Explanatory Statement: … Continue reading rounded up the implementation of the treaty-based final BEPS outcomes in one single document. MLI is aimed at providing a framework that could allow amending existing bilateral treaties at once, bringing them in…

FATCA, Tax Avoidance, Tax Fraud, Uncategorized, Withholding Taxes

(Texas A&M University Law)/ /10 Comments

I was recently asked to analyze the often quoted figure of $150 billion lost by the U.S. Treasury to foreign non-tax compliance by U.S. taxpayers.  My transcribed remarks are below.  Also, see William Byrnes’ Guide to FATCA & CRS Compliance (Matthew Bender 5th ed., 2017) at pp. 30, 33-34, 50, 59, 109-112, and 119-122. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2926119 How…

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(Bomchil)/ /Leave a comment

The path from bank secrecy to automatic exchange of information and beyond Giant steps towards international transparency: The 2008 and 2014 Milestones In 2015 OECD released its Update on Voluntary Disclosure Programs: A pathway to tax compliance, which was a renewed edition of the original survey published in 2010. The 2015 update was aimed at…

Tax Avoidance, Tax Fraud, Uncategorized

(Bomchil)/ /Leave a comment

Back in April this year, my contribution on the Panama Papers scandal started by saying that: “Massive leaks of information on offshore activity like the Panama Papers illustrate the need for enhanced global tax cooperation with an improved and deeper inter-jurisdictional information sharing scheme.”[1] It is not now my intention to follow the subsequent episodes…

BEPS, MAPs and APAs, OECD, State Aid, Tax Avoidance, Tax Planning, Transfer Pricing, Uncategorized

(Texas A&M University Law)/ /Leave a comment

On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here).  The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA) between the Netherlands Tax Authority (Tax Authority) and Starbucks Manufacturing BV (SMBV), a wholly owned and controlled coffee roasting operation. Below is the Part I…

Intangibles, Tax Policy, Tax Treaties, Uncategorized, Withholding Taxes

(Godoy & Hoyos Abogados)/ /1 Comment

Probably without noticing it, Colombia did not take into account that signing the recent DTT with France would allow some treaty-covered taxpayers to claim Most-Favoured-Nation (MFN) protection. Some of Colombia’s DTTs, as the ones signed with Spain, Chile, Switzerland, Portugal and Mexico, include Most-Favoured-Nation clauses with respect to royalties. In this sense, it is important…

BEPS, M&A and Reorganizations, MAPs and APAs, OECD, Permanent Establishments, Tax Avoidance, Tax Planning, Tax Policy, Tax Treaties, Uncategorized, Withholding Taxes

(CORIT advisory)/ /Leave a comment

1. The Tendency We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD, G20, EU countries and most other developed countries alike. This has led to continuously increasing regulatory requirements and strengthened legislation towards companies. The tendency is…

EC Tax Review, Uncategorized

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment

Volume 25 (2016) issue 2 contains: EDITORIAL: MICHAL AUJEAN, ‘Some Twenty-Seven Years after…’ Abstract: When I started writing this editorial a question quickly came to my mind: what have I been doing all these years that I devoted to taxation and more specifically to European tax policy? Then I thought it was time to say…