…administrations have published guidance on their approach to these issues. Indeed, almost immediately after the OECD also published helpful comment on them too. The general thrust is that circumstances forced…
…The Vagueness of Tax Fairness: A Discursive Analysis of the Commission’s ‘Fair Tax Agenda’ Unless treaties are read in very liberal terms, the European Union (EU) is not competent for…
…who may have been coming to India on a regular basis over the years, or have been Indian tax resident in the past. Therefore, given these circumstances, an exemption from…
…competent authorities may agree. Management changes resulting from the pandemic make the difficulties with this rule more acute. Hard pressed competent authorities may take more time than usual to deal…
…the individual free from control of the hiring company?; and (B) Is the individual providing a service that is not the hiring company’s core business?; and (C) Is the individual…
…compliance of the parent company with relevant tax laws; e) Costs which are ancillary to the corporate governance of the MNE as a whole. [2] Compared to the 2010 TPG,…
…question, it highlighted the complementary competence of the Commission and the national courts in respect of the State aid control: the former is exclusively entitled to decide on the compatibility…
…to perceive the outcomes as going way beyond the original intent of the standard[2]. It has promoted flexibility where comparables are not available and offered the theorization necessary to fill…
…sought to harmonize some of the rules governing the intra-EU trade as the European Commission pointed out that businesses engaged in cross-border trade incur 11% higher compliance costs than those…
…Shifting (BEPS) project of 15 reports. In 2005, ten years before the BEPS reports, the OECD published E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from…
…in Finnish companies? Firstly, although it is first and foremost the Finnish company’s liability to levy withholding tax on dividend payments, the threshold for retroactively claiming non-levied WHT from the…
…derives business income. Company S pays an arm’s length royalty to Company R. From a transfer pricing perspective, Company R is usually classified as a full-fledged manufacturer (FFM) whereas Company…
…the interposition of a Luxembourg resident company to own the Canadian company, which itself in turn was owned by the US investors. The case was of considerable significance to both…
…Public Comments, Uber, p. 10; Public Comments, Amazon, p. 8; Public Comments, Nestle, p. 12; Public Comments, Skadden, p. 6; Public Comments, Digital Economy Group, p. 5; Public Comments, KPMG,…
