Broken Deals and EU VAT
…Advocate-General Kokott delivered her opinion in Sonaecom (Case C-42/19) which also concerns a so-called ‘broken deal’. The litigant in this case, the Portuguese company Sonaecom, a mixed holding company, intended…
Search Results for: C_TFG61_2211考古题推薦 🍰 C_TFG61_2211試題 🦝 C_TFG61_2211考古題介紹 ✌ 打開▶ www.newdumpspdf.com ◀搜尋[ C_TFG61_2211 ]以免費下載考試資料C_TFG61_2211測試題庫
Duplicate Activities: An Excessive Burden on Taxpayers?
…OECD Public Comments, supra n 7, p. 7 and p. 95. [9] OECD Public Comments, supra n 7, p. 221. [10] OECD Public Comments, supra n 7, p. 83. [11]…
What Does the MLI Actually Do for PEs?
…Commissionaire type arrangements Art. 12.1 is like the new article 5.5 of the 2017 OECD MC, i.e. it qualifies commissionaires as PEs. Art. 12.3.a determines that article 12.1 shall replace…
Abuse of law, Anti-tax avoidance, Double non-taxation, Double Taxation, International Tax Law, Mauritius, MLI, Netherlands, OECD, Principal purpose test, Tax Avoidance, Tax Planning, Tax Treaties, Treaty shopping, United Kingdom
The relationship between treaties and domestic anti-abuse provisions
…controversial commentary on the relationship between domestic anti-abuse measures and tax treaties. It asserted that a general rule, there is no conflict between such rules and tax treaties (2003 Commentary…
Dong Yang Electronics (Case C-547/18): Oh Yes, a Subsidiary Can (also) Be a Fixed Establishment under EU VAT, but Information Asymmetries May Save You!
…its decision, whose findings instead pay consideration to “economic and commercial realities” as a “fundamental criterion for the application of the common system of VAT” (para. 31). Beside the one…
DAC 6 and Transfer Pricing: The Hallmark Concerning Unilateral Safe Harbours
…Commission Services within Working Party IV of the European Commission, according to which safe harbours should be regarded as “unilateral” only where they depart from the international consensus embodied in…
Market access based income tax on cross-border digital trades: A second best for the LATAM Region?
…Tax News Alert, European Commission publishes proposal for recovery plan and adjusts 2020 Work Programme https://globaltaxnews.ey.com/news/2020-5790-european-commission-publishes-proposal-for-recovery-plan-and-adjusts-2020-work-programme 13. For a critical appraisal of these source rules under the traditional source concept,…
Abuse of law, Anti-tax avoidance, International Tax Law, Principal purpose test, Tax Avoidance, Tax Treaties, Trusts and Estates, United Kingdom
The eye of the needle: Is one of your purposes tax avoidance?
…resident company wholly owned by a Bermuda resident insurance company. The Mauritian company purchased and developed land in the UK. The three individuals each took out a life insurance policy…
International Tax Competition in light of Pillar II of the OECD project on Digitalization
…setting competencies to another entity / international organisation. International tax competition development factors Development of tax competition is affected by numerous factors. One of them is the gradual elimination of…
Import of goods, revaluation and natural justice
…The facts of the case are straightforward. The taxpayer, a company incorporated under the Companies Act, 1956, imported certain raw materials (impure wax) from its US-based parent company between financial…
Beneficial ownership, Dividends, Financial institutions, Luxembourg, Switzerland, Tax Treaties, Withholding Taxes
Federal Supreme Court Denies Beneficial Owner Capacity of a Borrower of Swiss Shares Over a Dividend Payment Date
…arrangement between Lux Bank and a financial institution based in the United Kingdom (“UK Bank”), a sister company of Lux Bank. Both entities were controlled subsidiaries of a listed company…
Bumps in the level playing field
…It is, of course, commendable that the OECD addresses the discrepancy that existed between the substance requirements for preferential regimes on the one hand and low or no tax jurisdictions…
Swiss Supreme Court Rules on Pension Qualification Under Tax Treaty
…Law Convention Art. 31 para. 1 does not define any hierarchy among the interpretation principles, the starting point of the interpretation is the common meaning of the provisions. Such common…
Anti-tax avoidance, CFC, COVID-19, EU law, EU/EEA, International Tax Law, OECD, Principal purpose test
The Influence of the COVID-19 Pandemic on the Application of the OECD PPT, GAARs and (Some) SAARs: Lack of Substance for the Protection of Health
…the commentary on the OECD PPT, in which example company policy is taken into account when this is ‘conforming to the standard commercial organization and behaviour of the group’[8]. The…