…and corporate commercial. END NOTES [1] “The following expenses are not deductible from taxable income:…management, technical services and royalty fees paid to a non-resident person exceeding two percent (2%)…
…the contracting states. This language predates the introduction of the “foreseeably relevant” standard in the OECD Model in 2005. The term “necessary” meant that the competent authority of the requested…
…3, 2006) http://ana.blogs.com/maestros/2006/11/data_is_the_new.html (accessed Oct. 10, 2019). See The world’s most valuable resource is no longer oil, but data (Economist May 6, 2017). Available at https://www.economist.com/leaders/2017/05/06/the-worlds-most-valuable-resource-is-no-longer-oil-but-data (accessed Oct. 10, 2019)….
…not be appropriate to second guess if the Protocol is but a replacement for the MLI. Anyhow, it is indeed commendable that India and China bilaterally negotiated and concluded a…
…suffer tax at 40%.[4] Even if the dividend distribution tax of 15%[5] is factored, ownership of Indian company is not a tax-inefficient choice compared to foreign companies operating in India….
…statement that “while direct taxation, as EU law currently stands, falls within the competence of the Member States, they must nonetheless exercise that competence consistently with EU law”[4]. It is…
…subject of a sale and lease back to the IMSO. The IMSO later transferred its business to a commercial company. The Tribunal concluded that Inmarsat, the commercial company did not…
…strict if the fund participations are listed on the Amsterdam Stock Exchange. Dutch FII’s can have several different legal forms, such as limited liability company, public limited liability company, or…
…Commission.[33] Starbucks’ tax advisor undertook an analysis based on the criteria used by the Commission and of 87 companies identified, only three were the same as the Commission’s results relied…
…of the economy. Starting with defining what digitalization is, she then moved on to cover other topics such as problems with nexus in a digital world (identifying the compliance taxpayers,…
…through the holistic commercial rationality test which in the 2017 OECD TP Guidelines is a standard to recognise a transaction. The commercial rationality test, despite having the same wording as…
…is whether a registration obligation, which, by definition, can only apply to foreign companies and a penalty, which can only hit foreign companies that fail to comply with their registration…
…It pursues to overhaul the exercise of EU competences in the tax area and therefore multiply the potential of these competences. And yet it does not touch upon these competences….
…tax rates use company accounts as a data source. The most common measure of effective tax rates focuses on the tax charge rather than a preferable measure which is “cash…
