Mexican Tax Reform in between BEPS 1.0 and BEPS 2.0
…UPR, in a way, also illustrates the ambiguity of some of the tax policy choices of Pillar Two, as well as the complexity of the rules and the technical design…
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Taxation in the Future – A New EU: Vision and Impact
…on one of the heaviest tax portfolios in the history of the Commission and it is not questioned that it did well. The outgoing Commission has been the Commission to…
Double Taxation, EU law, EU/EEA, International Tax Law, Ireland, MNE Profits, OECD, Permanent Establishments, Tax Treaties, Transfer Pricing, United States
Disputed attribution of profits to Irish and United Kingdom branches or permanent establishments
…non-resident companies remined identical for decades until 2003. In each country, a non-resident company trading through a branch in that country was chargeable to corporation tax on trading income arising…
The Future of Transfer Pricing in Brazil
…http://www.sarocha.com.br/livros/BRAZIL-INTERNATIONAL-TAX-POLICY_Final.pdf. [3] The text is available at this link: http://kluwertaxblog.com/2019/07/30/brazilian-tp-missed-opportunities-ahead/. [4] See: Sergio André Rocha, Brazil’s International Tax Policy (Rio de Janeiro: Lumen Juris, 2017) p. 155-165. Available at: http://www.sarocha.com.br/livros/BRAZIL-INTERNATIONAL-TAX-POLICY_Final.pdf….
The Contents of Intertax, Volume 47, Issue 12, 2019
…financial transactions. (OECD, Public Discussion Draft Financial Transactions, BEPS Actions 8–10, (3 July – 7 Sept. 2018), https://www.oecd.org/tax/transfer-pricing/BEPS-actions-8-10-transfer-pricingfinancial-transactions-discussion-draft-2018.pdf (accessed 29 July 2019).) More recently, comments by an OECD representative have…
BEPS’ Bait & Switch: OECD Pillar II GloBE Comments and Recommendations
…using a common standard to calculate the tax base. A CCCTB type common consolidated tax base could significantly increase the complexity and cost of compliance of adding another layer of…
Hybrid Financial Instruments, Double Non-taxation and Linking Rules: (only some) issues stemming from the apparent ‘solution’
…have developed very complex rules (i.e. linking rules, see here, here, here and here) in an attempt to tackle some forms of DNT across borders. While battling DNT in general…
Dong Yang Electronics (Case C-547/18): Can a Subsidiary Be (also) a Fixed Establishment under EU VAT?
…things clear once and for all. Facts and Questions The background to the request for a preliminary ruling is that a company established in Korea (LG Korea) commissioned a third-party…
The DAC6 Intermediary: multiplying compliance-costs and creating loopholes
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was amended multiple times,…
Comments and Recommendations for the OECD “Unified Approach” to Digital Taxation
…new complexity arising from replacing the bedrock arm’s length principle (‘ALP’) for application of Article 7 and 9 of the OECD Model Tax Convention (‘MTC’). Our comments and recommendations of…
Dividends, Double Taxation, International Tax Law, Latin America, Netherlands, OECD, Personal income tax, Residence, Tax Treaties, United Nations, Withholding Taxes
Non- discrimination: The backpacker and the shareholder
…dividend article 10. At issue was whether dividends paid by a South African resident company to its parent company should be subject to withholding tax at the rate of 5%…
The Turkish Digital Service Tax is around the Corner
…public comments on certain aspect of the Global-Anti-Base Erosion Proposal under Pillar 2.[5] Similarly, on 21 March 2018, the EU Commission published a comprehensive legislative proposal laying down a new…
European VAT and the Sharing Economy*
…as European Value Added Tax (EU VAT), the VAT Committee – an advisory body inside the European Commission – has discussed certain issues specifically related to the treatment of sharing…
Tax Aspects of Migrations
The speed at which the world around us is changing combined with the novelty of the challenges our societies are faced with, seems to lead our policy makers towards what…