…length principle is only applied in a cross-border context, thereby impeding the free and competitive allocation of resources within the EU internal market and favouring domestic transactions. The second issue…
…Shipping Business. g) Holding Company Business. h) Intellectual Property Business. i) Distribution and Service Centre Business. [20] See Paragraphs 18 and 19 of OECD MC Commentary on Article 5. Concerning…
…their bilateral convention’. The UN MC Commentary on Article 5 merely reproduced these statements from the OECD MC Commentary on Article 5. [10] Notably, one may consider that since UAE…
…Report on Double Taxation (1923) (League of Nations, Economic and Financial Commission, Report on Double Taxation Submitted to the Financial Committee by Professors Bruins, Einaudi, Seligman and Sir Josiah Stamp,…
…ethyl alcohol. Court of Justice (Summary comment by Giorgio Emanuele Degani) (H&I 2023/60) – Exchange of information on movements of excise goods between Member States for commercial purposes (Summary comments…
…intangible something, and based on a multiple of studies, intangible assets by digital, data- and technology-driven companies might currently be overvalued. The potential consequences of such overvaluation could not only…
…excise duty, provided that such taxes comply with the Community rules applicable to excise duties or VAT in the matter of determining the tax base, calculation , chargeability and control…
…and passenger transport sector. In keeping with the principle of proportionality, the Commission proposed deemed supplier rules only in sectors where disruption of competition with the traditional sector is most…
…& Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the cornerstone of multinational enterprises’ (MNEs)…
…of international policy coherence and co-ordination. The OECD’s publicly stated plan going forward is to collect and then ‘produce comprehensive and systematic data, information, and tools to analyse the effects…
…Commission. [1] EUROPEAN Commission, COMMUNICATION FROM THE COMMISSON TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Business Taxation for the 21st Century, COM(2021) 251 final, (BEFIT initiative) pp. 11-13. [2]…
…[14C]. [16] OECD (n 1) 66. [17] PSLA 2015/4 (n 8) [16]. [18] ‘Comparison between audit and advance pricing arrangement features’, ATO (Web Page, 9 August 2022) <https://www.ato.gov.au/business/international-tax-for-business/in-detail/advance-pricing-arrangements/?page=4#Comparison_between_audit_and_advance_pricing_arrangement_features>. [19] OECD…
…State as an Alternative to DEBRA Basically, a company can be financed by debt or equity. The general national tax systems are that interest, the compensation paid for funds put…
…Rules and the compatibility of these rules with Tax Treaties, EU Tax Law and the broader international law framework. You can listen to the trailer below. http://wolterskluwerblogs.com/tax/wp-content/uploads/sites/59/2023/03/KLI-24-trailer-mp3.mp3 …
