…its services, a combination of hardware, software and human input, via a software platform ‘Aladdin’ whose functionality ranged from portfolio analysis, trade modelling, compliance and risk modelling, corporate actions, trading…
…developing countries which seek excessive transfer pricing adjustments for advertising. marketing and promotion expenses incurred by taxpayers. [1] Para 9.35 of the OECD Guidelines [2] https://www.lexology.com/library/detail.aspx?g=f74d1d32-afc3-402d-b56e-4f49ba354da6 [3] http://kluwertaxblog.com/2020/12/18/the-coca-cola-company-ruling-analysing-the-us-tax-courts-observations/ [4] https://core.ac.uk/download/pdf/224838774.pdf…
…company would not be subject to capital gains tax in India, since the shares of the Cayman Islands company were not located in India. The government found the judgement to…
…criterion of a similar nature’ remains a subject of contention Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII) (See for example http://kluwertaxblog.com/2020/02/27/alta-energy-treaty-shopping-is-no-abuse/ ) This central question was one…
…Mario Riedl, The Comparability Analysis of the Court of Justice of the European Union in the Light of the Aures Case The comparability analysis plays an important role in the…
…looks at analyzing Big Data to combat offshore tax evasion. The CRA continues to prioritize obtaining better data, improving its use of data to target its compliance actions, and achieving…
…impetus for the development of digital ITDR becomes more prominent considering the current Covid-19 pandemic. Furthermore, compared with dispute resolution mechanisms in many other domains, the ITDR process particularly lends…
…regular raising of capital by regular companies– there are no tax liabilities for any of the parties. However, if the ICO involved issuing utility tokens which come with an obligation…
…comparability adjustments (such as the accounting, balance sheet, etc.) are undertaken primarily to eliminate differences and to achieve greater comparability between the comparable transactions/companies selected and the controlled transactions/companies under…
…compromised, at least not among the companies that made up its client base. The Luxembourg court according found that PwC had undoubtedly suffered harm in the short term. However, no…
…parent company which holds resident subsidiaries, but is precluded for resident sister companies the common parent company of which is tax resident of the UK. [1] Trade and Cooperation…
…available at https://www.globalreporting.org/standards/media/2482/gri-207-tax-2019.pdf (accessed 02 May 2021). [15] For further details, see European Commission, Communication From The Commission To The European Parliament And The Council – Business Taxation for…
…MAP Statistics per jurisdiction (OECD) https://www1.compareyourcountry.org/map-statistics/en/0/2288+2289+2290+2291+2292+2293+2294/default (accessed 20 January 2021). [9] OECD: Action 14 – OECD BEPS, https://www.oecd.org/tax/beps/beps-actions/action14/ (accessed 5 May 2021). [10] Report on the US (para.123), OECD: Action…
…States income tax treaty on the basis that the UK company was not a “qualified person” by reason of article 23 (Limitation on benefits). Discretionary relief The UK company applied…
