…suited to indulge in treaty shopping in spite of PPT and LOB conditions. One such is the Protected Cell Company. The Protected Cell Company Protected Cell Companies (PCCs) are pre-structured…
…Volume 09. 2018. Available at: <https://www.mdpi.com/2078-2489/9/9/230/pdf>. [13] A deeper, perhaps more troublesome issue with treating AAI as an individual, involves giving AAI the same individual rights that taxpayers have in…
…the authors welcome comments from the international tax community on this blog. The authors would like to thank Mr Johann Muller, Mr Stefaan De Baets, Mr Balthasar Denger and Dr…
…of these strategies are not unknown to businesses and their tax advisers. The idea of the book is to communicate these to the common man (and the media) in a…
…Ottawa Conference first recognized that “e-commerce” was ushering fundamental changes to the global economy. It is not surprising that countries would wish to find ways and means to address their…
…that affect the competitiveness of the companies in the internal market, directly linked to the free movement rules and also relevant for the application of the State aid rules.” (emphasis…
…Competence to Tax: A Comparative Legal Study of Municipal Taxes in Belgium and the Netherlands This article describes and compares the possibilities under Belgian and Dutch law for taxation by…
…The EU Competition Commissioner and possible candidate for European Commission presidency, Margrethe Vestager, has called on European countries to take the lead, if global initiatives led by the OECD do…
…an investment committee of the general partner outside Australia; before making important decisions, an investment committee of the general partner took advice from the management company, RCF Management, outside of…
…nothing can be said to be certain, except death and taxes.” Franklin was right then and he is right now. However, there is one more commonality between death and taxes,…
…Unanimity for a Qualified Majority in the Tax Field”, focuses on the European Commission Communication to the European Parliament, the European Council and the Council, “Towards a more Efficient and…
…terms of combating tax avoidance, because it took the position that it was already compliant with BEPS, rejected the PPT, and did not sign the MAATM. But the 2017 tax…
…tax (‘CIT’) instead. While non-resident companies are subject to immediate taxation, resident companies could benefit from a cash-flow advantage when they remain in deficit, or even a permanent exemption when…
…it was principally possible for a Swiss holding company to undertake a tax-neutral demerger, such that the existing holding company could transfer just one qualifying participation in an underlying active…
